SEC Petition Evaluation Report

Petition SEC-00210 

Report Rev #: 0 Report Submittal Date: January 7, 2014 

Subject Expert(s): Pat McCloskey

Site Expert(s): N/A

Petition Administrative Summary

Petition Under Evaluation

Petition # Petition 

Type

Petition

Receipt Date Qualification Date DOE/AWE Facility Name

SEC-00210 83.13 March 12, 2013 July 1, 2013 Kansas City Plant

Petitioner-Requested Class Definition

All employees who worked at the Bannister Federal Complex from 1949 to present.

Class Evaluated by NIOSH

All employees who worked in any area of the Kansas City Plant site in Kansas City, Missouri, from January 1, 

1949 through December 31, 1993. 

NIOSH-Proposed Class to be Added to the SEC

None

Related Petition Summary Information 

SEC Petition Tracking #(s) Petition Type DOE/AWE Facility Name Petition Status

SEC-00110 83.13 Kansas City Plant Closed/Class not added

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name

N/A N/A

ORAU Lead Technical Evaluator: Pat McCloskey ORAU Peer Review Completed By: Michael Kubiak

Peer Review Completed By: [Signature on File] 1/7/2014

Pete Darnell Date

[Signature on File] 1/7/2014 SEC Petition Evaluation Reviewed By:

J. W. Neton Date

[Signature on File] 1/7/2014 SEC Evaluation Approved By:

Stuart L. Hinnefeld Date
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Evaluation Report Summary: SEC-00210, Kansas City Plant

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH)

addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the 

Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C. 

§ 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as 

Members of the Special Exposure Cohort under the Energy Employees Occupational Illness 

Compensation Program Act of 2000. 

Petitioner-Requested Class Definition

Petition SEC-00210 was received on March 12, 2013, and qualified on July 1, 2013. The petitioner 

requested that NIOSH consider the following class: All employees who worked at the Bannister 

Federal Complex from 1949 to present. 

Class Evaluated by NIOSH

Based on its preliminary research, NIOSH reduced the petitioner-requested class. NIOSH evaluated 

the following class: All employees who worked in any area of the Kansas City Plant site in Kansas 

City, Missouri, from January 1, 1949 through December 31, 1993. 

NIOSH-Proposed Class to be Added to the SEC 

Based on its full research of the class under evaluation, NIOSH has obtained monitoring records, 

process descriptions, and source term data for the evaluated class. Based on its analysis of these 

available resources, NIOSH found no part of the class under evaluation for which it cannot estimate 

radiation doses with sufficient accuracy. 

Feasibility of Dose Reconstruction

Per EEOICPA and 42 C.F.R. § 83.13(c)(1), NIOSH has established that it has access to sufficient 

information to: (1) estimate the maximum radiation dose, for every type of cancer for which radiation 

doses are reconstructed, that could have been incurred in plausible circumstances by any member of 

the class; or (2) estimate radiation doses of members of the class more precisely than an estimate of 

maximum dose. Information available from the site profile and additional resources is sufficient to 

document or estimate the maximum internal and external potential exposure to members of the 

evaluated class under plausible circumstances during the specified period.

Health Endangerment Determination

Per EEOICPA and 42 C.F.R. § 83.13(c)(3), a health endangerment determination is not required 

because NIOSH has determined that it has sufficient information to estimate dose for the members of 

the evaluated class.
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Table of Contents

1.0 Purpose and Scope .......................................................................................................................... 9

2.0 Introduction .................................................................................................................................... 9

3.0 SEC-00210, Kansas City Plant Class Definitions ........................................................................ 10

3.1 Petitioner-Requested Class Definition and Basis ................................................................ 10

3.2 Class Evaluated by NIOSH ................................................................................................. 11

3.3 NIOSH-Proposed Class to be Added to the SEC ................................................................ 11

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class ........................................................... 11

4.1 Site Profile Technical Basis Documents (TBDs) ................................................................ 12

4.2 ORAU Technical Information Bulletins (OTIBs) ............................................................... 12

4.3 Facility Employees and Experts .......................................................................................... 13

4.4 Previous Dose Reconstructions ........................................................................................... 14

4.5 NIOSH Site Research Database .......................................................................................... 15

4.6 Documentation and/or Affidavits Provided by Petitioners ................................................. 15

5.0 Radiological Operations Relevant to the Class Evaluated by NIOSH ......................................... 16

5.1 Kansas City Plant and Process Descriptions ....................................................................... 16

5.1.1 Kansas City Plant Site Description .......................................................................... 18

5.1.2 Kansas City Plant Process Description .................................................................... 20

5.2 Radiological Exposure Sources from Kansas City Plant Operations .................................. 25

5.2.1 Internal Radiological Exposure Sources from Kansas City Plant Operations ........ 25

5.2.1.1 Natural Uranium ....................................................................................... 25

5.2.1.2 Depleted Uranium .................................................................................... 25

5.2.1.3 Thorium .................................................................................................... 26

5.2.1.4 Thoron ...................................................................................................... 26

5.2.2 External Radiological Exposure Sources from Kansas City Plant Operations ....... 26

5.2.2.1 Photon ....................................................................................................... 28

5.2.2.2 Beta ........................................................................................................... 28

5.2.2.3 Neutron ..................................................................................................... 29

5.2.3 Incidents .................................................................................................................. 29

6.0 Summary of Available Monitoring Data for the Class Evaluated by NIOSH ............................. 30

6.1 Available Kansas City Plant Internal Monitoring Data ....................................................... 31

6.2 Available Kansas City Plant External Monitoring Data ...................................................... 35

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by NIOSH ...................................... 37

7.1 Pedigree of Kansas City Plant Data ..................................................................................... 38

7.1.1 Internal Monitoring Data Pedigree Review ............................................................. 38

7.1.2 External Monitoring Data Pedigree Review ............................................................ 38

7.2 Evaluation of Bounding Internal Radiation Doses at Kansas City Plant ............................ 39

7.2.1 Evaluation of Bounding Process-Related Internal Doses ........................................ 39

7.2.1.1 Urinalysis Information and Available Data .............................................. 39
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7.2.1.2 Airborne Levels ........................................................................................ 39

7.2.1.3 Alternative Data Sources for Bounding Internal Dose ............................. 39

7.2.2 Evaluation of Bounding Ambient Environmental Internal Doses ........................... 40

7.2.3 Methods for Bounding Internal Dose at Kansas City Plant .................................... 40

7.2.3.1 Methods for Bounding Operational Period Internal Dose ........................ 40

7.2.3.2 Methods for Bounding Ambient Environmental Internal Dose ............... 46

7.2.4 Internal Dose Reconstruction Feasibility Conclusion ............................................. 46

7.3 Evaluation of Bounding External Radiation Doses at Kansas City Plant ........................... 46

7.3.1 Evaluation of Bounding Process-Related External Doses ....................................... 47

7.3.2 Evaluation of Bounding Ambient Environmental External Doses .......................... 48

7.3.3 Kansas City Plant Occupational X-Ray Examinations ........................................... 48

7.3.4 Methods for Bounding External Dose at Kansas City Plant ................................... 49

7.3.4.1 Methods for Bounding Operational Period External Dose ....................... 49

7.3.4.2 Methods for Bounding Ambient Environmental External Doses ............. 50

7.3.5 External Dose Reconstruction Feasibility Conclusion ............................................ 50

7.4 Evaluation of Petition Basis for SEC-00210 ....................................................................... 51

7.4.1 Class Definition ....................................................................................................... 51

7.4.2 Promethium Contamination Incident ...................................................................... 51

7.4.3 DU Machining ......................................................................................................... 51

7.4.4 Unmonitored Exposure ............................................................................................ 51

7.5 Summary of Feasibility Findings for Petition SEC-00210 .................................................. 52

8.0 Evaluation of Health Endangerment for Petition SEC-00210 ...................................................... 52

9.0 Class Conclusion for Petition SEC-00210 ................................................................................... 53

10.0 References .................................................................................................................................... 55

Attachment One: Data Capture Synopsis .............................................................................................. 65

Tables 

Table 4-1: No. of Kansas City Plant Claims Submitted Under the Dose Reconstruction Rule ............ 14

Table 5-1: Kansas City Plant Building Information .............................................................................. 19

Table 5-2: Typical Radiation-Generating Devices ................................................................................ 27

Table 5-3: Types of Radiation Sources at Kansas City Plant ................................................................ 27

Table 6-1: Alpha Contamination Levels in DU Work Areas for 1962 to 1969 .................................... 31

Table 6-2: Statistical Parameters of Measured DU in KCP Workplace Air(a),(b) for 1958-1970 ........... 32

Table 6-3: Statistical Parameters of Recorded DU in Urine for 1959-1971(a) ...................................... 34

Table 6-4: Number of Recorded and Average Bioassay Measurements for 1959-1971 ....................... 35

Table 6-5: Statistical Parameters of Recorded Penetrating Annual Doses ............................................ 36

Table 7-1: Summary of Feasibility Findings for SEC-00210 ............................................................... 52
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Figures 

Figure 5-1: Map showing the location of KCP. .................................................................................... 17

Figure 5-2: NNSA/DOE and GSA properties at the BFC. .................................................................... 18

Figure 5-3: Image of a Gisholt Turret Lathe ......................................................................................... 22
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SEC Petition Evaluation Report for SEC-00210

ATTRIBUTION AND ANNOTATION: This is a single-author document. All conclusions drawn from 

the data presented in this evaluation were made by the ORAU Team Lead Technical Evaluator: Pat 

McCloskey, Oak Ridge Associated Universities (ORAU). The rationales for all conclusions in this 

document are explained in the associated text.

1.0 Purpose and Scope

This report evaluates the feasibility of reconstructing doses for all employees who worked in any area 

of the Kansas City Plant (KCP) site in Kansas City, Missouri, from January 1, 1949 through 

December 31, 1993. It provides information and analyses germane to considering a petition for 

adding a class of employees to the congressionally-created SEC. 

This report does not make any determinations concerning the feasibility of dose reconstruction that 

necessarily apply to any individual energy employee who might require a dose reconstruction from 

NIOSH. This report also does not contain the final determination as to whether the proposed class 

will be added to the SEC (see Section 2.0). 

This evaluation was conducted in accordance with the requirements of EEOICPA, 42 C.F.R. pt. 83, 

and the guidance contained in the Division of Compensation Analysis and Support’s (DCAS) Internal 

Procedures for the Evaluation of Special Exposure Cohort Petitions, DCAS-PR-004.1

2.0 Introduction 

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting that the 

Department of Health and Human Services (HHS) add a class of employees to the SEC. The 

evaluation is intended to provide a fair, science-based determination of whether it is feasible to 

estimate with sufficient accuracy the radiation doses of the class of employees through NIOSH dose 

reconstructions.2 

42 C.F.R. § 83.13(c)(1) states: Radiation doses can be estimated with sufficient accuracy if NIOSH 

has established that it has access to sufficient information to estimate the maximum radiation dose, 

for every type of cancer for which radiation doses are reconstructed, that could have been incurred in 

plausible circumstances by any member of the class, or if NIOSH has established that it has access to 

sufficient information to estimate the radiation doses of members of the class more precisely than an 

estimate of the maximum radiation dose.

 

Under 42 C.F.R. § 83.13(c)(3), if it is not feasible to estimate with sufficient accuracy radiation doses 

for members of the class, then NIOSH must determine that there is a reasonable likelihood that such 

radiation doses may have endangered the health of members of the class. The regulation requires 

NIOSH to assume that any duration of unprotected exposure may have endangered the health of 

 

1 DCAS was formerly known as the Office of Compensation Analysis and Support (OCAS). 2 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and 

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas.
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members of a class when it has been established that the class may have been exposed to radiation 

during a discrete incident likely to have involved levels of exposure similarly high to those occurring 

during nuclear criticality incidents. If the occurrence of such an exceptionally high-level exposure has 

not been established, then NIOSH is required to specify that health was endangered for those workers 

who were employed for at least 250 aggregated work days within the parameters established for the 

class or in combination with work days within the parameters established for one or more other SEC 

classes. 

NIOSH is required to document its evaluation in a report, and to do so, relies upon both its own dose 

reconstruction expertise as well as technical support from its contractor, Oak Ridge Associated 

Universities (ORAU). Once completed, NIOSH provides the report to both the petitioner(s) and the 

Advisory Board on Radiation and Worker Health (Board). The Board will consider the NIOSH 

evaluation report, together with the petition, petitioner(s) comments, and other information the Board 

considers appropriate, in order to make recommendations to the Secretary of HHS on whether or not 

to add one or more classes of employees to the SEC. Once NIOSH has received and considered the 

advice of the Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary 

of HHS will make the final decision, taking into account the NIOSH evaluation, the advice of the 

Board, and the proposed decision issued by NIOSH. As part of this decision process, petitioners may 

seek a review of certain types of final decisions issued by the Secretary of HHS.

3

 

3.0 SEC-00210, Kansas City Plant Class Definitions 

The following subsections address the evolution of the class definition for SEC-00210, Kansas City 

Plant. When a petition is submitted, the requested class definition is reviewed as submitted. Based on 

its review of the available site information and data, NIOSH will make a determination whether to 

qualify for full evaluation all, some, or no part of the petitioner-requested class. If some portion of the 

petitioner-requested class is qualified, NIOSH will specify that class along with a justification for any 

modification of the petitioner’s class. After a full evaluation of the qualified class, NIOSH will 

determine whether to propose a class for addition to the SEC and will specify that proposed class 

definition. 

3.1 Petitioner-Requested Class Definition and Basis

Petition SEC-00210 was received on March 12, 2013, and qualified on July 1, 2013. The petitioner 

requested that NIOSH consider the following class: All employees who worked at the Bannister 

Federal Complex from 1949 to present. 

The petitioner provided information and affidavit statements in support of the petitioner’s belief that 

accurate dose reconstruction over time is impossible for the KCP workers in question. NIOSH 

deemed the following information sufficient to qualify SEC-00210 for evaluation: 

Radiation exposures and doses potentially incurred by members of the proposed class were 

not monitored either through personal or area monitoring. 

 

3 See 42 C.F.R. pt. 83 for a full description of the procedures summarized here. Additional internal procedures are 

available at http://www.cdc.gov/niosh/ocas.
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Operations for which NIOSH has not found complete (i.e., limited internal) monitoring 

data include: 

• Cesium-137 work starting in 1949 (NIOSH is uncertain of the end date) 

• Uranium machining from 1951-1958 

• Thorium machining from 1961-1979 

Based on its KCP research and data capture efforts, NIOSH determined that it has access to 

monitoring records, process descriptions, and source term data for KCP workers during the time 

period under evaluation. However, NIOSH also determined that internal monitoring records are not 

complete for all time periods or for all radionuclides. The information and statements provided by the 

petitioner qualified the petition for further consideration by NIOSH, the Board, and HHS. The details 

of the petition basis are addressed in Section 7.4. 

3.2 Class Evaluated by NIOSH

Based on its preliminary research, NIOSH reduced the petitioner-requested class because the entire 

Banister Federal Complex is not a “covered facility” as defined by EEOICPA. Therefore for this 

evaluation effort, NIOSH can only consider the smaller Kansas City Plant located within the Bannister 

Federal Complex. In an attempt to determine the end date for the period qualifying for evaluation, 

NIOSH examined approximately 160 claims with employment in 1994 or later, coinciding with the 

Department of Energy (DOE) implementation of 10 C.F.R. pt. 835 radiological program requirements. 

The claims review indicated that many 10 C.F.R. pt. 835-era claims have no monitoring reported to 

NIOSH by DOE; however, this can be expected as not all KCP site employees may have reached the 

exposure-potential thresholds required for modern-era personnel monitoring. Of the 10 C.F.R. pt. 

835-era claims with no exposure monitoring data, the NIOSH review did not find any post-1993 

claims with apparent or potentially inadequately-monitored exposures. Therefore, NIOSH defined the 

following class for further evaluation: All employees who worked in any area of the Kansas City Plant 

site in Kansas City, Missouri, from January 1, 1949 through December 31, 1993. 

3.3 NIOSH-Proposed Class to be Added to the SEC

NIOSH has obtained monitoring records, process descriptions, and source term data. Based on its 

analysis of these available resources, NIOSH found no part of the class under evaluation for which it 

cannot estimate radiation doses with sufficient accuracy.

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class

As is standard practice, NIOSH completed an extensive database and Internet search for information 

regarding the Kansas City Plant site. The database search included the DOE Legacy Management 

Considered Sites database, the DOE Office of Scientific and Technical Information (OSTI) database, 

the Energy Citations database, and the Hanford Declassified Document Retrieval System. In addition 

to general Internet searches, the NIOSH Internet search included OSTI OpenNet Advanced searches, 

OSTI Information Bridge Fielded searches, Nuclear Regulatory Commission (NRC) Agency-wide 

Documents Access and Management (ADAMS) web searches, the DOE Office of Human Radiation 

Experiments website, and the DOE-National Nuclear Security Administration-Nevada Site Office-
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search. Attachment One contains a summary of KCP documents. The summary specifically 

identifies data capture details and general descriptions of the documents retrieved.

In addition to the database and Internet searches listed above, NIOSH identified and reviewed 

numerous data sources to determine information relevant to determining the feasibility of dose 

reconstruction for the class of employees under evaluation. This included determining the availability 

of information on personal monitoring, area monitoring, industrial processes, and radiation source 

materials. The following subsections summarize the data sources identified and reviewed by NIOSH. 

4.1 Site Profile Technical Basis Documents (TBDs) 

A Site Profile provides specific information concerning the documentation of historical practices at 

the specified site. Dose reconstructors can use the Site Profile to evaluate internal and external 

dosimetry data for monitored and unmonitored workers, and to supplement, or substitute for, 

individual monitoring data. A Site Profile consists of an Introduction and five Technical Basis 

Documents (TBDs) that provide process history information, information on personal and area 

monitoring, radiation source descriptions, and references to primary documents relevant to the 

radiological operations at the site. The Site Profile for a small site may consist of a single document. 

As part of NIOSH’s evaluation detailed herein, it examined the following site profiles for insights into 

Kansas City Plant or related topics/operations at other sites: 

• Site Profile for the Kansas City Plant, ORAUT-TKBS-0031; Rev. 00 PC-1; January 6, 2006; 

SRDB Ref ID: 20217 

• Site Profiles for Atomic Weapons Employers that Worked Uranium Metals, Battelle-TBD-6000; 

Rev. 01; June 17, 2011; SRDB Ref ID: 101251 

4.2 ORAU Technical Information Bulletins (OTIBs) 

An ORAU Technical Information Bulletin (OTIB) is a general working document that provides 

guidance for preparing dose reconstructions at particular sites or categories of sites. An ORAU 

Procedure provides specific requirements and guidance regarding EEOICPA project-level activities, 

including preparation of dose reconstructions at particular sites or categories of sites. NIOSH 

reviewed the following OTIBs as part of its evaluation:

• OTIB: Dose Reconstruction During Residual Radioactivity Periods at Atomic Weapons Employer 

Facilities, ORAUT-OTIB-0070; effective March 5, 2012; SRDB Ref ID: 108851

• OTIB: Dose Reconstruction from Occupationally Related Diagnostic X-Ray Procedures, ORAUTOTIB-0006, Rev. 04; effective June 20, 2011; SRDB Ref ID: 98147

• OTIB: Estimation of Ingestion Intakes, OCAS-TIB-009, Rev. 0; effective April 13, 2004; SRDB 

Ref ID: 22397

• OTIB: Use of Coworker Dosimetry Data for External Dose Assignment, OCAS-TIB-0020, Rev. 3; 

effective November 14, 2011; SRDB Ref ID: 104029
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4.3 Facility Employees and Experts

To obtain additional information relevant to KCP operations, NIOSH interviewed 19 former KCP

employees. NIOSH’s specific objective was to gain an understanding of specific operations with 

radioactive materials conducted at KCP and to identify any radiological monitoring performed during 

KCP operations. 

• Personal Communication, 2013a, Personal Communication with KCP Health Physicist; Interview 

by ORAU Team and NIOSH; August 27, 2013; SRDB Ref ID: 127865

• Personal Communication, 2013b, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127871

• Personal Communication, 2013c, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127869 

• Personal Communication, 2013d, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127875 

• Personal Communication, 2013e, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127868 

• Personal Communication, 2013f, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127873 

• Personal Communication, 2013g, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127863 

• Personal Communication, 2013h, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127878 

• Personal Communication, 2013i, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127872 

• Personal Communication, 2013j, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127877 

• Personal Communication, 2013k, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127876

• Personal Communication, 2013l, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127864

• Personal Communication, 2013m, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 29, 2013; SRDB Ref ID: 127874
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• Personal Communication, 2013n, Personal Communication with KCP Employee; Interview by 

ORAU Team and NIOSH; August 29, 2013; SRDB Ref ID: 127866

• Personal Communication, 2013o, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 29, 2013; SRDB Ref ID: 127870 

• Personal Communication, 2013p, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 29, 2013; SRDB Ref ID: 127867 

• Personal Communication, 2013q, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 29, 2013; SRDB Ref ID: 128746 

• Personal Communication, 2013r, Personal Communication with KCP Employee; Interview by 

ORAU Team and NIOSH; October 16, 2013; SRDB Ref ID: 128743

• Personal Communication, 2013s, Personal Communication with Former KCP Employee; 

Interview by ORAU Team and NIOSH; August 29, 2013; SRDB Ref ID: 128748 

• Personal Communication, 2013t, Personal Communication with KCP Health Physicist; e-mail 

correspondence by ORAU Team; September 4, 2013; SRDB Ref ID: 127657 

• Personal Communication, 2013u, Personal Communication with KCP Employees; e-mail 

correspondence by ORAU Team; November 27, 2013; SRDB Ref ID: 129196 

4.4 Previous Dose Reconstructions

NIOSH reviewed its NIOSH DCAS Claims Tracking System (referred to as NOCTS) to locate

EEOICPA-related dose reconstructions that might provide information relevant to the petition 

evaluation. NIOSH reviewed each claim to determine whether internal and/or external personal 

monitoring records could be obtained for the employee. Table 4-1 summarizes the results of this 

review. (NOCTS data available as of November 22, 2013) 

Table 4-1: No. of Kansas City Plant Claims Submitted Under the Dose Reconstruction Rule

Description Totals

Total number of claims submitted for dose reconstruction 672

Total number of claims submitted for energy employees who worked during the period under 

evaluation (January 1, 1949 through December 31, 1993) 665

Number of dose reconstructions completed for energy employees who worked during the period

under evaluation (i.e., the number of such claims completed by NIOSH and submitted to the 

Department of Labor for final approval). 608

Number of claims for which internal dosimetry records were obtained for the identified years in the 

evaluated class definition 35

Number of claims for which external dosimetry records were obtained for the identified years in the 

evaluated class definition 103
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4.5 NIOSH Site Research Database

NIOSH also examined its Site Research Database (SRDB) to locate documents supporting the 

assessment of the evaluated class. The database contained 1,645 documents that were identified as 

pertaining to the KCP site. These documents were evaluated for their relevance to this petition. The 

documents include historical background on monitoring and program descriptions (e.g., air 

monitoring, urinalysis data, radiation and surface contamination surveys, radiological control program 

information, medical monitoring, process materials, and process descriptions).

4.6 Documentation and/or Affidavits Provided by Petitioners

In qualifying and evaluating the petition, NIOSH reviewed the following documents submitted by the 

petitioners:

• Form B for the Kansas City Plant, also contains four affidavits; received March 12, 2013 and 

qualified July 1, 2013; DSA Ref ID: 118659

• Employee Verification-Affidavit from Former KCP Employee; March 5, 2013; DSA Ref ID: 

118733 

• Report of Investigation of Pm-147 Contamination, February 10, 1989; Allied-Signal Aerospace 

Company; Published September 1989; DSA Ref ID: 118938

• Supporting Document: Pm-147 Exhibit, select pages; DSA Ref ID: 118941-118986

• Kansas City Plant: Nuclear Reactor Development and Testing and Atomic Bomb Manufacturing 

Capability; received June 15, 2013; DSA Ref ID: 119031

• Petition Response to May 10, 2013 Request; June 16, 2013; DSA Ref ID: 119033

• Attachment 10, Comparison of NIOSH, DOL and Site Investigator’s Perspective Pm-147 Incident, 

first draft; compiled by Cold War Soldiers; DSA Ref ID: 119034

• Preliminary Support Document and Records Request and Inspection List; received July 25, 2013; 

DSA Ref ID: 119153
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5.0 Radiological Operations Relevant to the Class Evaluated by 

NIOSH

The following subsections summarize both radiological operations at the KCP site from January 1949 

to December 1993 and the information available to NIOSH to characterize particular processes and 

radioactive source materials. From available sources NIOSH has gathered process and source 

descriptions, information regarding the identity and quantities of each radionuclide of concern, and

information describing processes through which radiation exposures may have occurred and the 

physical environment in which they may have occurred. The information included within this 

evaluation report is intended only to be a summary of the available information. 

5.1 Kansas City Plant and Process Descriptions 

KCP is located at the Bannister Federal Complex (BFC) within the city limits of Kansas City, 

Missouri. The BFC is located approximately 10 miles south of the city center (see Figure 5-1) at 2000 

E. 95th Street, Kansas City, MO 64131. BFC is a compact, highly-developed site (consisting of 

approximately 300 acres) owned by the National Nuclear Security Administration (NNSA) and the 

General Services Administration (GSA) (see Figure 5-2). NNSA was established by Congress in 

2000 as a separately organized agency within the United States DOE, responsible for the management 

and security of the nation’s nuclear weapons, nuclear nonproliferation, and naval reactor programs. 

KCP consists of about 122 acres and 38 buildings. For the period evaluated by NIOSH, the KCP

workforce varied; however, it consisted of approximately 2,700 workers on average (DOE, May2013). 

The workforce peaked at 8,000 during the arms build-up in 1985. In addition, there is a transient 

population of construction contractor personnel (AlliedSignal, Mar1995, pdf p. 18). 

The primary contractor that operated KCP starting in 1949 was Bendix Aviation Co. Bendix then 

merged with Allied Corporation in 1982, and in 1984, Allied Corporation merged with the Signal 

Companies to form Allied-Signal Aerospace, Inc. In 1999, Allied-Signal Aerospace merged with 

Honeywell International and formed Honeywell Federal Manufacturing and Technologies to operate 

KCP.
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Figure 5-1: Map showing the location of KCP. 

Source: DOE, May2013
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Figure 5-2: NNSA/DOE and GSA properties at the BFC. 

Source: DOE, May2013

5.1.1 Kansas City Plant Site Description 

NNSA owns the portion of the BFC known as KCP, consisting of about 122 acres and 38 buildings. 

The 38 buildings NNSA owns comprise about 2.9 million square feet (see Table 5-1). About 90 

percent of this area is industrial space, 2 percent is warehouse space, and 8 percent is office, cafeteria, 

and administrative space.

The most dominant structure on the BFC is the Main Manufacturing Building, which has about 2.7 

million square feet of contiguous space and houses the primary KCP manufacturing operations. 

NNSA and GSA share this space. NNSA has control of approximately 1.75 million square feet of 

space in this building. In addition to the Main Manufacturing Building, NNSA owns about 1.2 

million square feet of space in the remaining 37 buildings. 

The KCP buildings vary in type of construction, ranging from steel and concrete to masonry. They 

were built at various times and with different design criteria. The Main Manufacturing Building 

structure uses load-bearing arches, each 40-foot wide, constructed with movable concrete forms. It 

represents one of the largest integrated projects in the war construction program, virtually under a 

single roof. 
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With the exception of the Main Manufacturing Building, the buildings are predominately one- and 

two-story brick and cast-stone industrial structures with flat roofs. KCP includes smaller structures 

that relate directly to the history and significance of the complex in support of production operations. 

Other buildings, while linked to the complex by their utilitarian nature, are prefabricated metal or 

reinforced concrete, with many being open-air shelters and guard posts (DOE, May2013).

GSA owns the remainder of the BFC, consisting of about 175 acres and 14 buildings. Major 

highways (Interstate Highway 435 [I-435] and I-49/U.S. Highway 71) and auxiliary and smaller 

secondary streets provide access. There are no residences or agricultural activities or farmlands on the 

BFC. There is a daycare facility located on GSA property. The adjoining properties to KCP and the 

BFC are mostly residential with isolated commercial tracts, except along the eastern and northern 

sides, which have been designated for public and recreational uses (DOE, May2013).

Table 5-1: Kansas City Plant Building Information

Building Name Building 

No.

Year 

Built

Area

(ft2) Construction Type

Main Manufacturing Building 1 1942 1,755,593 Reinforced concrete

Main Office Building 2 1942 240,717 Reinforced concrete

West Powerhouse 5 1943 60,760 Reinforced concrete

Manufacturing Support Building 13 1957 142,516 Steel framed with unreinforced 

masonry block

Four Experimental Test Cells 14 1943 40,077 Reinforced concrete

Polymer Building 15 1943 18,991 Reinforced concrete

Kinematics Building 16 1942 5,331 Steel framed

Unfinished Test Cells 46 1943 5,509 Reinforced concrete

East Powerhouse 48 1961 12,958 Steel framed

High Power Lab 54 1944 31,309 Steel framed

Waste Management 59 1952 24,120 Prefabricated metal

Solid Waste Disposal 73 1972 8,868 Prefabricated metal

Production and Chemical Storage 74 1973 27,294 Pre-engineered metal with 

unreinforced masonry 

Supervisory Control 75 1973 2,294 Reinforced concrete

Oil Storage Building 77 1948 2,319 Steel framed with unreinforced 

masonry block 

North Wing Laboratory 86 1943 28,624 Reinforced concrete frame

Forge and Casting 88 1943 35,960 Reinforced concrete building

Fire Protection Pump House 89 1991 1,904 Steel framed

Mold Heating and Cooling 90 1984 2,400 Reinforced masonry

Plating Building 91 1985 38,113 Steel framed

Technical Transfer Center 

(Building 92) 92 1985 258,229 Steel framed 

Special Process Building 96 1987 13,585 Steel framed

Industrial Waste Pretreatment 

Facility 98 1988 21,988 Steel framed

Receiving Dock 01-B 1987 3,650 Masonry

Main (West) Switchgear 01-C 1942 2,400 Reinforced masonry

East Employee Entrance 9 1942 1,884 Masonry

Central Guard Post 32 1974 1,043 Steel framed

North Employee Entrance 47 1942 1,747 Masonry
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Table 5-1: Kansas City Plant Building Information

Building Name Building 

No.

Year 

Built

Area

(ft2) Construction Type

Storage Shed 68 1957 576 Steel framed

Explosive Storage Bunker 76 1953 150 Reinforced concrete

East Guard Post 78 1974 413 Steel framed

West Guard Post 79 1974 200 Steel framed

North Guard Post 80 1974 454 Steel framed

Test Cells 87 1943 132,596 Reinforced concrete

Northeast Guard Post 93 1985 191 Steel framed

Northwest Guard Post 94 1987 240 Steel framed

Receiving and Shipping Security 

Post 99 2004 305 Steel framed

Air Monitoring Building 31 1994 208 Steel framed

Total 2,925,516

Source: This table is a slightly modified version of Table 1-1 in DOE, May2013. 

5.1.2 Kansas City Plant Process Description 

Note: Some information concerning the history of KCP nuclear weapons assembly activities involves 

classified information; therefore, a clear description of all activities is not publicly available. The 

primary KCP work activity involving radiation exposure was fabrication and quality-control testing of 

components of nuclear weapons (ORAUT-TKBS-0031).

Historically, the area occupied by KCP was primarily agricultural, except for a brief period during the 

1920s when it was an automobile racetrack. In 1942, the Federal Government built the Main 

Manufacturing Building for the U. S. Navy, which Pratt and Whitney used to manufacture airplane 

engines during World War II in 1945. 

After the war ended, from 1945 through 1949, the government used the KCP facility as both a storage 

facility for tires, raw rubber, sugar, and lumber and as a facility to house government operations. 

Under contract with the U.S. Navy, Westinghouse built jet engines in part of the facility from 1948 

through 1961. 

The Bendix Aviation Co. began producing electrical and mechanical weapon components for the U.S. 

Atomic Energy Commission in part of the Main Manufacturing Building in 1949 and expanded its use 

of the facilities after Westinghouse left. Since that time, the principal operation at KCP has been the 

manufacture of nonnuclear components of nuclear weapons, which involves metals and plastics 

machining, plastic fabrication, plating, microelectronics, and electrical and mechanical assembly 

(DOE, May2013). 

Cesium-137 Work 

NIOSH reviewed one trip report covering a visit to Bendix Aviation Co. on May 25, 1949, 

indicating that “gap tubes” containing Cs-137 were produced by Bendix (Trip Report, 1949). At 

the time of petition SEC-00210 qualification, NIOSH was unable to determine if KCP was the 

location of Bendix gap tube production. Since SEC-00210 qualified, through further research as 

corroborated by interviews of former workers, NIOSH has determined that gap tube 
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manufacturing did not occur at KCP (Personal Communication, 2013c, 2013d, 2013g, 2013h, 

2013l, 2013n, 2013p). NIOSH has determined that the Bendix Aviation Co. discussed in the trip 

report was most likely the Eclipse-Pioneer Division of Bendix Aviation Co. in Teterboro, New 

Jersey (the Bendix Division where a manager referenced in the report worked as the Safety 

Director) (Cone, 1950). A document listing the radioactive materials in the KCP plant (KCP, 

1950-1963) states that the gap tubes in question (M-26-3) were only handled as an assembled item 

for a short time and in a controlled manner. A document detailing experience with radioactive 

sources prior to 1954 (Schiltz, Aug1962) indicates that gap tubes received from the vendor were 

already assembled. NIOSH has found no evidence that gap tubes were manufactured at KCP; 

however, there are reports that Bendix Aviation Co. did manufacture gap tubes in New Jersey 

(Schiltz, Jun1962; Grant, 1962). 

Natural Uranium Operations 

NIOSH has information that KCP workers inspected and assembled uranium components, 

machined uranium slugs, and handled uranium billets and ingots at KCP in the early 1950s. 

Starting in May 1950 and continuing to February 1955, uranium components were inspected and 

assembled in Department 3A (KCP, 1950-1963). In February 1951, KCP set up a machine shop to 

produce 1,000 slugs per day to fuel AEC production reactors at the Savannah River Site in South 

Carolina, and Argonne National Laboratory near Chicago, Illinois. KCP received some of the 10-

foot long uranium rod stock for this work from the Lackawanna Test Site in New York. Fortyfive thousand (45,000) slugs were produced for the initial order. Ongoing work to produce 5-tons 

per month was also scheduled. The work was performed in the Main Manufacturing Building in 

Department 49X, also known as Area X. This area was specifically prepared for this work: a 

smooth finished concrete floor was laid and painted, steel panel walls were erected, an adjacent 

storeroom was prepared, and the entire area was cleaned and painted. The equipment used to 

make slugs in this area included: an 8'' Springfield bench lathe; a Fay Automatic lathe; a Schauer 

air collet machine; a power cut-off saw; and four Gisholt turret lathes (see Figure 5-3). Work was 

performed during two shifts utilizing machine operators (14), inspectors (3), an accountability 

officer, and a packaging man (Mahaffey, 1952; Paine, 1951). 
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Figure 5-3: Image of a Gisholt Turret Lathe

Source: Mahaffey, 1952

The 1.062-inch diameter uranium rods were shipped to KCP already straightened. There, using a 

power hacksaw, the bar ends were sawed off. The bars were placed in the Gisholt turret lathes and 

turned to 1-inch diameter and cut in 8.120-inch lengths. These rough slugs were then fed into the 

Fay Automatic lathe where they were turned to the finished diameter of 0.997-inches and the 30-

degree cone chamfer was cut. The final operation was to generate the 0.050-inch to 0.070-inch

radius using the Schauer air collet machine and a mill file. If any re-work was necessary, it was 

performed on the 8-inch Springfield bench lathe (Mahaffey, 1952). 

Machining uranium rods into slugs continued in 1952. KCP received unstraightened rods that 

were rolled at Bethlehem Steel and then KCP sent the slugs they made from those rods to Argonne 

National Laboratory and the Savannah River Site (Paine, 1951; Laing, 1952). These uranium slug 

machining operations came to an end at KCP in December 1952. 

Also in 1952, KCP machined and handled natural uranium in the form of billets and ingots 

destined for AEC facilities at the Lake Ontario Ordinance Works in Youngstown, New York; 

Allegheny Ludlum in Watervliet, New York; and the Fernald site in Harrison, Ohio (Malone, 

Feb1952; Malone, Mar1952; Hobert, 1953; Harshman, 1952). 
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Magnesium Thorium Alloy Machining

NIOSH has information indicating that beginning May 1, 1957 (KCP, 1950-1963) and continuing 

into 1979, as part of the RADEC weapons program, KCP machined and fabricated classified items 

with a magnesium thorium alloy (Mg-Th) in the Main Manufacturing Building. 

The Mg-Th that KCP used was the alloy known as HK-31, supplied by the Dow Chemical 

Company with a nominal 3% thorium content (Mg-Th, 1957-1970 pdf pp. 7, 22). 

The areas where KCP performed operations with Mg-Th were in the Model Shop (also known as 

Department 851, later renamed Department 823) and in Department 20. The equipment that was 

used included a Van Norman mill, a CSIP Hydroptic 6A vertical-jig boring-machine, a Kearney & 

Trecker Milwaukee die mill, a Tape lathe, and a Heli-arc welder (Mg-Th, 1962-1975).

Depleted Uranium (DU) Operations 

The first report of DU handling at KCP was in April 1958; however, DU machining began on 

September 9, 1958 (KCP, 1950-1963, pdf p. 12). KCP used the Machining Area (formerly known 

as Department 20) for the machining and inspection of DU products. KCP’s use of DU oxide is 

described as follows:

(Depleted) Uranium powder was mixed with an encapsulant and placed on another part and 

allowed to dry. Once dry the part was machined. This activity was limited to the Department 20 

(D/20) area and was never placed into production (DOE, Mar2013).

The Machining Area, covering about 12,000 ft2 in the Main Manufacturing Building, was “cleaned 

and decommissioned” in the early 1970s after completion of DU production operations (Rockwell, 

1987, pdf p. 106). However, there remained measurable levels of fixed radioactivity in sumps, 

floor drains, piping, floor expansion joints, and other surface areas. DOE remediated this area in 

phases and completed the final decontamination so that it met industrial standards by September 3, 

1986 (ORAUT-TKBS-0031). 

NIOSH has reviewed sample results taken during D&D activities in the area where KCP machined 

both Mg-Th and DU. The sample analysis was gamma spectroscopy for uranium isotopic 

composition and for specific activity. Gamma-ray intensities at energies of 93 keV attributable to 

Th-234, and 185 keV attributable to U-235 were evaluated to characterize the uranium enrichment 

of the material. The sample analysis showed that the Th-234/U-235 gamma ratio was typical of 

DU (Rockwell, 1987, pdf p. 50).

The primary workplace exposure over the entire history of KCP was associated with machining 

items containing DU oxide from 1958 to about 1971; the program that used DU oxide ended in 

1972 (ORAUT- TKBS-0031). No uranium was processed again until 1997 when a new program 

was initiated. 

KCP also used commercially available products that contained DU as shielding for a radiography 

unit (DOE, May2013). 
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Thorium Oxide Powder Operations 

NIOSH has located a KCP reference that was included as part of a chronological list of radioactive 

material at KCP, and the reference reads, “July 23, 1958 to July 1959 – Thorium oxide ThO2

powder was handled in the plant” (KCP, 1950-1963, pdf p. 12). Inventories of radiological 

sources were also found and the inventories show that KCP used some ThO2 sources and that KCP 

made a thorium nitrate solution at a rate of 20 grams per year (Rad Inventory, 1989). With the 

information that NIOSH currently has available, including personal communication with KCP site 

experts (Personal Communication, 2013u), it appears that KCP ThO2 operations were limited to 

laboratory analysis and solution preparations used in analytical procedures. 

In 1963, the GSA acquired ownership of the Bannister Federal Complex from the U.S. Navy. 

Excluded from this property acquisition were 8 buildings which were transferred directly to the 

Atomic Energy Commission (AEC). 

In 1976, the GSA transferred ownership of the remaining parcel, known as the Kansas City Plant, to 

the AEC. 

In 1983 a cleanup of the Bannister Federal Complex began with an assessment of previous use of the 

site and remediation. From 1984 through 1987, the DOE Albuquerque Operations Office initiated the 

Comprehensive Environmental Assessment and Response Program to identify, evaluate, and conduct 

remedial actions at sites including the Kansas City Plant. 

In the spring of 1984, KCP contracted with Rockwell International Corporation to perform major 

facility Decontamination and Decommissioning (D&D) of the Main Manufacturing Building 

(Rockwell, 1985). This D&D work was performed in three phases. Phase I began May 29, 1984, and 

was a site survey conducted to locate buried waste trenches and to measure radiological activity both 

in the trenches and in the Machining Area. Phase II began August 7, 1984, and involved the 

decontamination of the trenches and Machining Area and was completed on November 7, 1984. 

Radioactive materials (finely divided, DU oxide powder and DU metallic solid forms) were expected 

to be present in the trenches (Rockwell, 1985, pdf p. 36). However, radiological contamination was 

not observed at the trenches and radioactive or hazardous waste was not found in the surrounding soil 

(Rockwell, 1985, pdf p. 13). Some additional work was necessary because of a leaky sump that

required removal of a pipe and some soil, which delayed Phase III. Phase III began August 15, 1986, 

and was completed September 3, 1986, and involved decontamination of the Inspection Area portion 

of the Machining Area (Rockwell, 1987). During all three phases, Rockwell noted in their final 

reports that the decontamination requirements imposed by KCP management were below NRC and 

American National Standards Institute requirements for release of an area for unrestricted use 

(Rockwell, 1985).

At the request of KCP, an estimate of the total amount of uranium removed from the KCP site was 

made by the Rockwell Manager of Radiation and Nuclear Safety. The amount was determined to be 

approximately 16.62 kg. This estimate was based on the mass of the contaminated concrete and its 

average activity. “As only concrete surfaces were measured, this value should be considered to be a 

high estimate”.(Rockwell, 1985, pdf p. 54).
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In 1989, DOE and the Environmental Protection Agency (EPA) entered into a Corrective Action 

Administrative Order of Consent (VII-89-H-0026) under the authority of Section 3008(h) of the 

Resource Conservation and Recovery Act (RCRA). The Consent Order requires the evaluation of 

releases of hazardous wastes and their constituents and remedial measures (corrective actions) to be 

implemented to protect human health and the environment at the DOE Kansas City Plant. The 

Consent Order initially listed 35 solid waste management units (SWMUs), which were defined as 

possible release sites. Eight more were added after the Consent Order for a total of 43. From 1989 

through present, sampling and analysis of soil, groundwater, and air quality continue to ensure the 

effectiveness of remediation activities.

In 1993, DOE officially designated KCP as the consolidated site for all non-nuclear components for 

nuclear weapons. KCP currently manufactures or procures a wide array of sophisticated non-nuclear 

mechanical, electronic, and engineered material components for national defense systems. These 

components comprise about 85 percent of the components of a nuclear weapon (DOE, May2013; 

Maroncelli, 2002).

5.2 Radiological Exposure Sources from Kansas City Plant Operations

The following subsections provide an overview of the internal and external exposure sources for the 

KCP class under evaluation.

5.2.1 Internal Radiological Exposure Sources from Kansas City Plant Operations 

The primary potential source of internally deposited radioactivity resulting from KCP operations was 

inhalation and ingestion of uranium and thorium. This section addresses alpha-emitting radionuclide 

exposures at KCP. 

5.2.1.1 Natural Uranium

In the early 1950s, as described in Section 5.1.2 of this report, KCP personnel worked with natural 

uranium metal during slug and billet handling and during machining operations. KCP machined a 

total of 313,070 pounds of uranium metal into slugs and had the capacity to produce 1,000 slugs per 

day. KCP’s slug machining was undertaken as a short-term (22 month) project to demonstrate KCP’s

ability to improve slug-finish quality with turret lathes (O’Leary, 1951). 

Natural uranium refers to uranium consisting of approximately 99.3% U-238, 0.7% U-235, and a very 

small residual amount of U-234, by weight. In terms of radioactivity, natural uranium contains 

approximately equal percentages of U-238 (48.6%) and U-234 (49.2%). These radionuclides emit 

alpha particles with primary emission energies of 4.20 MeV and 4.15 MeV (U-238), and 4.77 MeV 

and 4.72 MeV (U-234) (Rad Handbook, 1970). The radioactivity contribution from U-235 is much 

smaller (approximately 2.2%) relative to U-238 or U-234. Uranium-235 emits alpha particles with 

energies of 4.40 MeV and 4.37 MeV. 

5.2.1.2 Depleted Uranium

KCP had substantial quantities of DU oxide at the site from April 1958 to about 1971 until the 

program that used DU oxide ended in 1972. They machined items coated with a film of DU oxide in 

Department 20 (DOE, Mar2013, pdf p. 6) beginning September 9, 1958 (KCP, 1950-1963, pdf p. 12). 
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The final decontamination of Department 20 (where this work was performed) was completed on 

September 3, 1986 (ORAUT-TKBS-0031). 

Order number ICO-020757 (Purchase Order, 1962) shows that KCP procured 10,000 pounds of UO2. 

Specification Control No. 4542260-00 (Ulitchny, 1998) dictated the minimum density should be no 

less than 10.8 g/cm3

, the surface area of the powder should be no greater than 1.1 m2/g, at least 97% 

by weight of the material should be less than 10 μm in diameter, and 100% by weight should be less 

than 15 μm in diameter. These specifications are consistent with a powder having an activity median

aerodynamic diameter (AMAD) of 1.175 μm and a geometric standard deviation (GSD) of 2.48 

(ORAUT-TKBS-0031).

In 1997, a new program was initiated where DU metal was reduced in size and shape by an 

electrochemical process that involves the placement of DU metal in an acid bath. The parts are rinsed 

with water and dried before handling. Because the uranium does not become volatile during the 

electrochemical process, remaining in the acid solution, there is minimal personnel internal dose 

hazard with this process. There is also no removable contamination with this process (ORAUTTKBS-0031). 

5.2.1.3 Thorium 

KCP performed Mg-Th operations in two areas of the Main Manufacturing Building (the Model Shop 

and Department 20) from May 1, 1957 to April 5, 1979 (Mg-Th, 1962-1975; Monitoring, 1963-1967; 

Rad Handling, 1987). Information presently available to NIOSH, including personal interviews and 

project plans, indicates that KCP Mg-Th operations were not a large-scale project and were 

undertaken on a “temporary basis” (Mg-Th, 1962-1975). As stated in one report, “The KCP has 

always been involved in special “piece-work,” that is, numerous, small, isolated projects relying on 

high-quality machining” (DOE, Mar2013, pdf p. 9). 

5.2.1.4 Thoron 

As indicated above, KCP performed limited thorium work. NIOSH has not identified monitoring data 

for the thorium daughter-product thoron during the evaluated period. However, NIOSH has identified 

gross alpha air monitoring data with results for both short and long lived activity that can be used to 

estimate thoron air concentrations.

5.2.2 External Radiological Exposure Sources from Kansas City Plant Operations 

The primary sources of workplace radiation fields at KCP are historically associated with processes 

involving industrial radiation-generating devices (e.g., X-ray machines and electron accelerators) (see 

Table 5-2); isotopic beta, gamma-ray, and neutron radiation-emitting sources (see Table 5-3). Table 

5-3 includes source inventory lists from 1964 and 1987 to illustrate the change over time. Significant 

changes from 1964 to 1987 are from extensive earlier use of radium sources and the presence of the 

230-Ci Cs-137 instrument calibration source in 1987. The isotopic sources were typically used in the 

manufacturing or quality control processes to monitor fabrication of non-nuclear weapons 

components. 
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Table 5-2: Typical Radiation-Generating Devices

Devices Energy (keV) Types Typical Use Period of Use

Industrial X-ray units 50 to 2,000 (X-ray) Rooms & Cabinets Radiography of parts 1950s to 2004

DXT Devicea 12 to 200 (X ray) Cabinets Density thickness 1960s to 1980s

DXT Device Cs-137 (1 Ci) Cabinets Density thickness 1960s to 1980s

Electron Beam Welders 35 to 150 (X-ray) Cabinets Welding small parts 1960s to 2004

Electron Microscopes 30 to 200 (X-ray) Cabinets Analysis 1960s to 2004

Electron Beam Vacuum

Deposition Systems 10 (X-ray) Cabinets Plating metals 1960s to 2004

Neutron generators 14.7 MeV (neutron) Open & Cabinets Generate microsec pulsed 

radiation 1960s to 2004

Neutron source Pu-239/Be (73 mCi) Cabinets Boron-10 analysis 1966 to 2004

Gamma camera Co-60 (19 Ci) Exposure Room Test electronic products 1950s to 1960s

Febetron Accelerator 2,300 (X-ray) pulser Cabinets Irradiation of electronic

components 1970s to 1980s

Cesium Irradiators Cs-137 (230 Ci) Exposure Room 

Calibration of radiation

detection instruments 1950s to 1980s

Medical X-ray 125 (X-ray) Exposure Room Patient diagnostic tests 1960s to 1990s

Electro Curtain 175 (X-ray) Cabinet Radiation curing of 

adhesives 1980s to 1990s

Source: This table is a slightly modified version of Table 4 in ORAUT-TKBS-0031.

Table 5-3: Types of Radiation Sources at Kansas City Plant

Nuclide Use

Source 

Inventory Lists

Predominant Radiation

1964 1987 Type

Major Energies, 

keV

C-14 Calibration source, beta scope, thickness 

gauges 

X X Beta 45-156 

Fe-55 Testing X Gamma bremsstrahlung to 

230 

Co-60 Calibration sources X Gamma 1,170, 1,330 

Ni-63 Gas chromatograph X Beta 67 

Sr-90 Calibration, thickness gauges X Beta 546 

Tc-99 Calibrations X Beta 292 

Tl-204 Beta scope, thickness gauges X Beta 766

Cd-109 Plating thickness gauge X Gamma 88

Ba-133 Neutron generator X Gamma 30-382

Cs-137 Calibration sources X X Beta 514-1,176

Gamma 662

Pm-147 Calibration sources, thickness gauges X Beta 70-256

Tl-204 Beta scope, thickness gauges X Beta 766

Radium Calibration sources, thickness gauges X X Alpha 4,600-4,780

Gamma 186-610

Uranium Calibration sources Alpha/gamma progeny radiations

from Th-230, Ra-226, etc.

Pu-239 Calibration sources, boron analysis X X Alpha 5, 110-5, 160

Gamma 39-770

Source: This table is a slightly modified version of Table 3 in ORAUT-TKBS-0031.
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Based on information available to NIOSH, KCP had the potential for external radiation (photon/beta) 

exposure from uranium and thorium source material, their decay products, and small amounts of 

surface contamination present after operations ceased. 

The following subsections provide an overview of the external exposure sources at KCP. 

5.2.2.1 Photon 

The uranium at KCP was derived from naturally-occurring metals, and thus exhibited a natural 

isotopic abundance except for the DU. 

Uranium emits both beta particles (electrons) and photons (gamma and X-rays). The two primordial 

components of natural uranium are U-238 and U-235, but some of their decay products grow into 

equilibrium fast enough to contribute to worker exposures during metal processing. External 

exposures to photon radiation would have resulted from the immediate daughter radionuclides in the 

uranium decay chain. The uranium progeny that result in the most significant photon exposures 

include Th-234 and Pa-234m (Rad Handbook, 1970). Note that these isotopes have relatively short 

half-lives and can be assumed to be in equilibrium with the parent U-238. Because of their short halflives, the exposure potential from these isotopes would follow the parent and will not be considered 

separately in this document. 

Uranium-235 emits alpha particles and gamma photons in about 70% of its transitions, but occurs at 

0.720% abundance in natural uranium. 

The majority of the photons from natural uranium metals are in the 30-250 keV energy range 

(Battelle-TBD-6000). However, solid uranium objects provide considerable shielding of the 

lower-energy photons and “harden” the spectrum, causing the majority of photons emitted from a 

solid uranium object (e.g., a slug or rod) to have energies greater than 250 keV. While it is recognized 

that solid uranium sources will have a hardened photon spectrum, exposure to a thin layer of uranium 

on a surface will result in a larger fraction of exposure to lower-energy photons (Battelle-TBD-6000). 

The beta and photon emissions of the radionuclides of major external exposure concern can be found 

in most standard health physics reference documents. Exposure to these emissions was possible for 

the period under evaluation during metal-handling and from submersion in contaminated air. 

Therefore, for the purposes of this evaluation, deep-dose estimates from the uranium sources at KCP 

are evenly distributed between photons with E=30-250 keV and photons with E= >250 keV. 

Thorium has a significant number of higher-energy photons in the Th-232 decay chain. Based on the 

half-lives of the progeny, only a partial equilibrium is possible; therefore, it is conservative to state 

that equilibrium would be reached in this decay chain. It has been assumed that Ra-228 and Th-228 

progeny were in equilibrium with Th-232. Under this assumption, the progeny are the major source 

of both penetrating and non-penetrating external exposure. 

5.2.2.2 Beta

Beta particle radiation was the dominant source of external radiation exposure associated with 

uranium-machining activities at KCP, primarily from U-238 decay products. For example, nearly the 
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entire beta radiation field from DU comes from the daughter radionuclide Pa-234m, and to a lesser 

extent from Th-234. The surface beta dose-rate from a uranium slab is approximately 233 mrad per 

hour. 

Beta doses to the skin, extremities, and (sometimes) the lens of the eye can be limiting in facilities that 

process uranium. Potentially significant skin exposure from uranium occurs primarily from the 

Pa-234m beta particles at tissue depths of 4 mg/cm2 and greater. At 2.29-MeV (Emax), beta particles 

from Pa-234m are the most energetic contributors to the beta exposure. 

There are a significant number of high-energy betas representing a shallow dose concern for KCP 

workers. Workers who handled the uranium metal at KCP would have received these shallow doses. 

The primary exposure areas would have been the hands and forearms, the neck and face, and other 

areas of the body that were not covered. 

5.2.2.3 Neutron 

Sources of neutron radiation at KCP involved Karman Model A-800 pulsed-neutron generators and 

nuclide (alpha, neutron) interactions, such as 239PuBe sources, as listed in Table 5-3. Based on a 

review of workplace hazards, the first presence of neutron-emitting nuclides apparently occurred after 

1965 (ORAUT-TKBS-0031).

5.2.3 Incidents 

Promethium-147 Incident, February 10, 1989 

Pm-147 is a relatively low-energy, 100% beta-emitting nuclide (e.g., maximum energy of 224.7 keV, 

average energy of 62 keV) with a half-life of 2.6 years. The primary concern with this type of nuclide 

would be direct skin contamination and intake.

Pm-147 sources were used to measure film thickness at KCP. Failure of the integrity of one of these 

sources resulted in some minor skin contamination and was the subject of an official investigation; 

however, there were no personal internal exposures. On Friday, February 10, 1989, loose radioactive 

contamination was discovered on top of an X-ray fluorescent unit in Department 456, NonDestructive Test (NDT) Laboratory. This discovery was made during a routine radiological survey of 

an X-ray fluorescent unit by two industrial hygiene personnel. 

Subsequent investigation identified loose radioactive contamination on a nearby laboratory stool and 

on the hand of a member of the survey team. Further checks revealed contamination in the following 

areas: the NDT Laboratory; the D/456 office area directly above the NDT Laboratory; the stairway 

connecting the NDT Laboratory area and the D/456 office area; D/33, Precision Pattern Assembly 

Area (Room E) containing beta backscatter equipment; and one employee's residence.

Decontamination activities conducted by the DOE-Albuquerque Complex and Rockwell International 

health physics teams revealed that loose radioactive contamination in the previously mentioned areas 

was extensive and widespread. Rockwell International, by using gamma spectral analysis, positively 

identified samples of KCP contamination as Pm-147. This contamination was caused by fragile and 

unsealed Pm-147 sources, fabricated by Oak Ridge National Laboratory, which had been treated as 
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sealed by KCP. Inadequate monitoring and control failed to reveal that these Pm-l47 sources were 

unsealed prior to this investigation. 

According to an extensive investigation report, DOE, EPA, and Missouri Department of Health, 

Radiological Health Division representatives were notified at the time of this incident. A DOE team 

of investigators arrived at KCP on February 14, 1989, to assume technical management of the 

situation. The analytical laboratory that evaluated 97 urine samples from KCP personnel had initially 

reported 4 of those samples as having activity. A few days later the laboratory determined that they 

had made an error and there was actually no activity present in any of the samples (AlliedSignal, 

1989). The homes of [redacted] KCP workers were inspected and some contamination was found in 

one home. That home was decontaminated, the cause and extent of the contamination was 

determined, and corrective actions were put in place to prevent reoccurrences. 

Erbium Tritide Incident, September 30, 1987 

On August 12, 1987, a W80 Data Analyzer that contained erbium tritide was received from Sandia 

National Laboratory. On September 30, 1987, a KCP worker removed the analyzer’s protective 

cover. The analyzers were known to be exposed to tritium during operational testing at Sandia; 

however, they were normally decontaminated prior to returning them to KCP for follow-up testing. 

The outside cover had a visibly clean appearance, but when the worker removed the cover it was 

apparent that the interior was not cleaned as was required. The cover was immediately replaced and 

the Health and Safety group was contacted. The next day, swipe samples were taken inside and 

outside of the cover of the assembly and taken from nearby work surfaces. Contamination was only 

detected on the inside of the cover at 986 dpm/100 cm2. The W80 Data Analyzer was returned to 

Sandia National Laboratory for decontamination. Urinalysis was performed for the worker who 

opened and closed the case and the results indicated that there was no detectable activity for tritium as 

erbium tritide (solubility class M from International Commission on Radiological Protection (ICRP) 

Publication 71). As a result of this incident, procedures were upgraded at Sandia National Laboratory 

and KCP to ensure that similar incidents would not occur in the future (Tritium Incident, 1987). KCP 

Health Physics personnel were asked about this incident in August 2013, and they informed NIOSH 

that this incident was unique and did not reoccur (Personal Communication, 2013t).

6.0 Summary of Available Monitoring Data for the Class Evaluated 

by NIOSH

KCP has developed and maintained a radiological records database that contains records for all 

monitored worker exposures at KCP for all years of record. The database contains internal and 

external exposure data for approximately 4,400 workers. KCP has provided NIOSH a summary of 

internal and external dosimetry results from 1950 to 2003. It provides the number of individuals’ 

monitored, annual mean and maximum external exposure, shallow external dose, as well as bioassay 

results for uranium. Individual results are obtainable if employee numbers are known (Monitoring, 

1950-2003). NIOSH has not discovered any information indicating that radiological work was 

performed at KCP before the first personal monitoring (external) began in 1950.

The following subsections provide an overview of the state of the available internal and external 

monitoring data for the KCP class under evaluation. Details regarding the various analyses used and 

the associated minimum detectable activities are presented in ORAUT-TKBS-0031. 
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6.1 Available Kansas City Plant Internal Monitoring Data

Discussed below are the surface contamination data, air monitoring data, and bioassay data currently 

available to NIOSH.

Surface Contamination Data

NIOSH has results from routine quarterly contamination surveys performed in the main processing 

areas of the Main Manufacturing Building. Table 6-1 summarizes these alpha contamination results 

from 1962 to 1969 in work areas considered to be most significant for potential worker exposure 

(KCP, 2004). Table 6-1 is formed from more than 84 routine surveys, each containing multiple data 

points. Additionally, NIOSH has recently obtained copies of more than 150 alpha contamination 

surveys for 1959 through 1969 (Monitoring, 1960; Monitoring, 1959-1960; Monitoring, 1965-1969) 

and 20 quarterly contamination surveys for 1990 through 1994 (Monitoring, 1990-1996).

Table 6-1: Alpha Contamination Levels in DU Work Areas for 1962 to 1969

Facility Work Area

Measured Levels (dpm/100 cm2)

Average Maximum

D/34C (D/27C) 

Air lock 226 20,000

Locker room 570 7,000

General area 2,564 45,000

D/220-22 

(D/443-20D D/216-22, 

D/217-20D)

Air lock 190 800

Wash-up 180 650

General area 425 1,000

D/22, D/20D 

Air lock 206 350

Clean area 468 2,000

General area 892 16,000

Source: This table is a slightly modified version of Table 10 from ORAUT-TKBS-0031.

Air Monitoring Data

NIOSH has found a Safety Survey report showing that the air was sampled by a representative of the 

AEC’s Santa Fe Operations Office during the natural uranium machining operations in August 1952 

(Safety Survey, 1952, pdf p. 8). The report from this safety survey states: 

Atmospheric dust analysis and general observation within the Machining of Uranium Metal Area 

indicated that personnel are being properly safeguarded. The dust count in the lathe area during 

cutting operations was well below any limit wherein the toxicity might be considered. Some 

smoke and oxides were noticed, but the hood ventilation appeared to be adequate. Assembly Area 

dust samples were negative and the neatness of the area was impressive.

From 1958 to 1971, KCP workplaces were routinely monitored with air sampling for DU 

concentrations using gross alpha counting. Air samplers running at rates of 1 or 2 cfm were placed 

around the machining/processing areas of the Main Manufacturing Building. It is evident that KCP 

attempted to place these air samplers in locations where the sampled air would be representative of the 

air breathed by the workers. For example, there are annotations on air sample logs that state air 

samples were taken in areas such as “in the breathing zone” or “5-feet above floor level, in working 

area.” Air samples were also annotated when higher-risk work was performed, such as containment 
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window replacement (Monitoring, 1958-1961, pdf p. 85). KCP used fixed-filter air samplers that

operated continuously during operations; however, there are indications that these samplers were 

turned off at night and weekends when there was no work being performed (ORAUT-TKBS-0031; 

Monitoring, 1963-1967; Monitoring, 1958-1970; Monitoring, 1970-1971; Monitoring, 1962-1969; 

Monitoring, 1958-1961; Monitoring, 1969-1970). Following July 26, 1971, there are no workplace 

air sampling data available for analysis; however, intakes of DU are not likely after this time because 

of a process change from machining to the acid-etch procedure described in Section 5.2.1.2 of this 

report. 

Table 6-2 lists the maximum measured workplace airborne concentrations used to calculate the 

median and 95th percentile statistical parameters. The parameters in Table 6-2 were based on 

maximum measured air concentrations at several locations in the plant. Some measurement locations 

were identified only by a number. When locations were indicated, most were near the walls of the 

work areas. Other locations were labeled as: Mixing Rm, West, Air Lock, Over Shower, Rubber Mill 

Rm, Mill Stack West, and Dispersion Roll.

Table 6-2: Statistical Parameters of Measured DU in KCP Workplace Air(a),(b) for 1958-1970

KCP Measured Results(a) Lognormal Fit

Air Concentration

Year No. of 

Measurements

Mean

(μCi/cm3)

Maximum

(μCi/cm3)

Median

(μCi/cm3)

95%

(μCi/cm3) GSD

1958 22 7.18E-12 4.90E-11 4.01E-13 1.74E-10 4.02E+01 

1959 27 8.82E-13 1.22E-11 2.89E-13 2.53E-12 3.74E+00 

1960 33 1.32E-12 1.50E-11 3.41E-13 3.94E-12 4.43E+00 

1961 31 1.00E-12 2.04E-11 1.97E-13 1.52E-12 3.46E+00 

1962 31 7.73E-13 1.13E-11 2.50E-13 2.03E-12 3.58E+00 

1963 31 1.25E-12 1.63E-11 2.47E-13 1.90E-12 3.46E+00 

1964 31 2.21E-12 3.90E-11 3.91E-13 2.98E-12 3.44E+00 

1965 31 1.99E-13 8.70E-13 1.05E-13 8.02E-13 3.45E+00 

1966 23 7.01E-13 6.24E-12 2.00E-13 2.00E-12 4.06E+00 

1967 22 1.40E-12 1.30E-11 5.70E-13 3.12E-12 2.81E+00 

1968 19 1.21E-12 9.88E-12 2.31E-13 3.47E-12 5.19E+00 

1969 19 1.88E-11 8.55E-11 3.88E-12 1.42E-10 8.92E+00 

1970 19 7.32E-14 5.91E-13 4.02E-14 1.98E-13 2.64E+00 

Average 1958-1970 2.85E-12 2.15E-11 5.49E-13 2.62E-11 

Source: This table is a slightly modified version of Table 11 from ORAUT-TKBS-0031.

(a) All departments. (b) Based on maximum measured KCP workplace airborne uranium concentrations at several monitoring locations.

In 1970, KCP conducted a study of Mg-Th machining operations in the Model Shop and maintained 

airborne levels during this test at background (0 cpm recorded) for long-lived activity, and <3.22E-9 

μCi/ml for short-lived activity. As part of this test, each machining operation was performed with 

breathing-zone air samplers running (Mg-Th, 1962-1975, pdf p. 16). 
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Bioassay Data

Urine assays were found for August 11, 1959 to December 10, 1971 (Monitoring, 1950-2003; 

Monitoring, 1963-1970; Monitoring, 1964-1967; Monitoring, 1969-1971a; Monitoring, 1959-1971; 

Monitoring, 1969-1971b). KCP workers were individually monitored for DU intake from 1959 to 

1971 using a fluorophotometric method to measure the level of uranium in urine. A KCP document 

(KCP, 1962) states that the method is sensitive to concentrations of uranium from 5 E-11 to 1 E-10 g 

per 0.25 g of sodium fluoride with a precision of ±10%. This sensitivity equates to 0.5 to 1 μg U/L of 

urine. However, this sensitivity may be the theoretical best based on ultra pure water blanks, as 

opposed to urine blanks. The urine volume used for bioassay analysis was 0.1 ml and the lowest 

quantity of uranium used to determine a standard curve was 1 E-9 g. The urine concentration that 

equates to the lowest uranium quantity of the standard curve is 10 μg/L. Bioassay data for four 

individuals (ORAUT-TKBS-0031) show that concentrations as low as 1 μg U/L were recorded. 

However, most sites using fluorophotometry at this time were claiming more modest detection levels; 

for instance, Hanford claimed 4 μg/L, Paducah claimed 10 μg/L, and University of Rochester (used by 

many AWEs) claimed 5-10 μg/L (ORAUT-TKBS-0031). Because a definitive statement of the 

detection limit achieved by the Kansas City Plant was not found, an MDA of 10 μg/L is 

recommended.

By procedure (KCP, unknown date), the workers in radiation areas were to submit urine samples for 

uranium urinalysis on a semi-annually basis (May and November). Samples were then evaluated in 

KCP’s Industrial Hygiene Laboratory (Monitoring, 1969-1971b, pdf p. 12) using a written procedure 

(KCP, 1962). Bioassay data were recorded on either the individual’s film badge envelope or the 

annual 3-inch x 5.5-inch radiation exposure record (ORAUT-TKBS-0031). The actual frequency of 

bioassay analysis for KCP personnel who worked with DU powders varied from person-to-person and 

from year-to-year (ORAUT-TKBS-0031). The date and results of individual bioassay results are in 

each individual’s dosimetry file.

KCP created a database of bioassay data and shared with NIOSH a spreadsheet summary of the 

available data (Nasca, 2004a). There are numeric sums of all bioassay measurement results taken 

during the year for an individual; however, the number of bioassay measurements that comprise the 

annual sum is not recorded in the spreadsheet. 

Bioassay data from four individuals were studied (Monitoring, 1958-2005) to better understand KCP’s 

monitoring frequency and recordkeeping practice. The number of bioassay samples taken per year 

ranged from 0 to 6. Zero samples per year means that there are gaps in the bioassay record where one 

or more years of no bioassay data are bracketed by years for which there are bioassay data. 

Table 6-3 summarizes an analysis of the electronic bioassay records (ORAUT-TKBS-0031). These 

data show a peak in 1960 and 1961. The peak is apparently not the result of an incident, but could be 

due to a large number of bioassay samples being collected in those years for each worker (ORAUTTKBS-0031). The bioassay data for 1971 are very low; indeed, they are less than the sensitivity level. 

The low bioassay levels may indicate that no intakes of uranium occurred during that year. As noted 

above, the excreta data in Table 6-3 represent the sum of an unstated number of bioassay 

measurements. 
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Table 6-3: Statistical Parameters of Recorded DU in Urine for 1959-1971(a)

Year

Recorded Annual Urine 

Concentration(b)

Lognormal Fit

Chronic intakes (pCi/d)(c) No. of 

Workers 

Reported

Concentration (μg/L) Concentration (μg/L)

Mean Maximum Median GSD 5th Median 95th

1959 214 4.125 52.60 2.642 2.675 1.05E+02 6.42E+02 3.92E+03 

1960 281 36.58 140. 19.53 3.813 7.79E+02 4.75E+03 2.89E+04 

1961 123 51.40 192.1 37.44 2.402 1.49E+03 9.10E+03 5.55E+04 

1962 148 4.327 15.75 3.162 2.508 1.26E+02 7.69E+02 4.69E+03 

1963 211 10.96 72.00 7.564 2.532 3.02E+02 1.84E+03 1.12E+04 

1964 219 5.627 78.38 3.888 2.431 1.55E+02 9.46E+02 5.76E+03 

1965 175 9.572 38.00 5.583 3.422 2.23E+02 1.36E+03 8.27E+03 

1966 223 6.432 45.05 4.214 2.640 1.68E+02 1.02E+03 6.24E+03 

1967 159 5.438 21.50 3.574 2.713 1.43E+02 8.69E+02 5.30E+03 

1968 11 6.055 6.600 6.052 1.029 2.42E+02 1.47E+03 8.97E+03 

1969 <10 0.15 0.150 0.150 1.000 5.99E+00 3.65E+01 2.22E+02 

1970 59 11.64 45.00 7.576 2.686 3.02E+02 1.84E+03 1.12E+04 

1971 47 0.03596 0.1000 0.02993 1.903 1.19E+00 7.28E+00 4.44E+01 

ALL 1,871 14.1 192.1 5.5 4.7 

Source: This table is a slightly modified version of Table 12 in ORAUT-TKBS-0031.

(a) All bioassay measurements. (b) The recorded annual sum of urine concentration is the sum of all bioassay results for the year. There is one sum for 

each person-year record. The listed statistics are based on the analysis of the data, which are the sums of all bioassay data 

for every person for that year.

(c) Chronic intakes that produce the urinary excretion per day on the 365th day of intakes corresponding to the median 

excretion from the lognormal fit and 5th and 95th percentile intakes using a GSD of 3. Assumes 5-μm AMAD particle 

size and absorption type S; intakes for 1-μm AMAD particle size, 10.97 g/cm3 density, and absorption type S are smaller.

The workers who received bioassay for uranium had Organization Codes 530001 and 531002. Table 

6-4 lists the number of bioassay results for the two organizations and the occupations that had 

bioassay results. The Organization Code does not provide much information about what groups might 

have been exposed to airborne uranium because Code 531002 refers to the DOE contractor that 

operated KCP (e.g., Bendix, Allied-Signal), and Code 530001 refers to DOE workers. The Managers 

and Administrators occupation category included individuals who performed job estimates and who 

were commonly in the work areas. The data in Table 6-4 indicate that nearly all types of KCP

workers participated in the urinalysis program. Table 6-4 also lists the average of the bioassay

measurements for each occupational code.
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Table 6-4: Number of Recorded and Average Bioassay Measurements for 1959-1971

Occupation Description

Occ 

Code

Number of Individual 

Measurements

Bioassay 

Measurements 

Ave.(a) (μg/L)

Organization 

Code

530001

Organization 

Code 

531002

Managers and administrators 110 10 342 9.12

Engineers 160 228 8.85 

Scientists 170 15 2.34 

Health physicists 184 <10 4.30 

Miscellaneous professionals 200 17 8.80 

Repair technician 350 44 13.19 

Health technician 360 <10 5.39 

Technologist, engineering 370 38 13.66 

Miscellaneous technicians 390 47 8.90 

Administrative support/clerical/work planners 450 60 11.96 

Fire fighter 512 58 3.94 

Security inspector & guard 513 <10 <10 1.61 

Food service employees 521 <10 0.00 

Custodian/janitor 524 11 2.85 

Mechanics/repairers 610 350 7.68 

Electrician 643 153 8.97 

Pipe fitter 645 177 8.85 

Machinist 681 152 14.08 

Sheet metal worker 682 <10 0.00 

Operators, plant/system/utility 690 <10 1.23 

Machine setup/operators 710 <10 28 7.97 

Welders/solderers 771 11 7.01 

Miscellaneous precision/production workers 780 14 640 10.54 

NA(b) 781 <10 14.05 

Drivers 840 28 7.75 

Handlers/laborers/helpers 850 145 8.82 

All groups 9.44 

Source: This table is a slightly modified version of Table 13 in ORAUT-TKBS-0031.

 (a) Average of recorded bioassay measurements.

(b) NA indicates that information is not available.

6.2 Available Kansas City Plant External Monitoring Data

KCP has an electronic database with portable document format (PDF) files for individual monitored 

employees. For the years 1950 through 2010, doses are recorded for 4,500 KCP employees on 15,300 

records (DOE, 2010). Positive deep, shallow, and extremity doses were first recorded in 1950 

(Monitoring, 1950). Recorded extremity dose was higher in 1951 and 1952, than in any other years. 

Before about 1959, the recorded deep and shallow doses were essentially equal. Relatively high 

shallow dose (in comparison with deep dose) was recorded from 1959 to 1964 and during 1973. 

NIOSH also has copies of KCP dosimeter processing reports with dosimeter reads for employees and 

area monitors. The records are reported by Landauer and Eberline. 

The external dosimeters used at KCP are described in Section 7.3.1 of this report. 
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KCP positive neutron doses were first recorded in 1966 and recorded a total of 35 times over a period 

from 1966 through 1996. Most of the work at KCP that included neutron exposures occurred in the 

1980s (Monitoring, 1974-1978; Monitoring, 1967-1983). In all cases, except for two, the recorded 

annual deep dose is equal to the recorded annual neutron implying all recorded deep dose resulted 

from the neutron dose. The two exceptions occurred in 1976 and 1983 with recorded deep and 

neutron annual doses of 64 mrem and 26 mrem, and 3 mrem and 1 mrem, respectively. Overall, the 

recorded neutron dose is a relatively insignificant component of the worker dose. 

NIOSH examined KCP dose records and noted that some dose has been recorded for nearly all 

occupational categories at KCP. Based on information from e-mail correspondence (Nasca, 2004b), 

some doses in the KCP radiological records system have been assigned to workers even though 

investigations at the time of measurement have shown unexplainable causes. 

Table 6-5 summarizes KCP recorded annual penetrating dose, the arithmetic average and maximum 

value for all recorded penetrating doses, and the lognormal probability statistical parameters for all 

positive recorded doses (i.e., dose > 0). 

Table 6-5: Statistical Parameters of Recorded Penetrating Annual Doses

Year

Arithmetic, All Recorded Dose Lognormal, Dose>0

No. of 

Workers

Dose, rem Dose, rem

Mean Maximum GSD

No. of 

Workers Median 95%

1950 46 7.09E-02 6.47E-01 29 5.01E-02 5.54E-01 4.31E+00

1951 227 2.78E-01 5.32E+00 158 4.97E-02 2.02E+00 9.52E+00

1952 233 1.91E-01 5.90E+00 220 2.45E-02 7.42E-01 7.96E+00

1953 103 1.37E-01 5.32E+00 72 2.13E-02 4.50E-01 6.38E+00

1954 65 1.61E-01 2.99E+00 21 1.19E-01 4.74E+00 9.39E+00

1955 41 9.18E-02 4.18E-01 25 1.10E-01 4.59E-01 2.39E+00

1956 26 2.89E-01 1.75E+00 26 1.35E-01 1.07E+00 3.52E+00

1957 65 5.24E-01 7.89E+00 36 1.77E-01 6.33E+00 8.80E+00

1958 301 3.90E-02 8.43E-01 89 5.44E-02 4.84E-01 3.78E+00

1959 464 8.97E-03 2.30E-01 72 3.57E-02 1.78E-01 2.66E+00

1960 1,043 1.21E-02 1.35E+00 165 4.53E-02 2.31E-01 2.70E+00

1961 948 2.39E-02 5.90E-01 400 3.17E-02 1.64E-01 2.72E+00

1962 700 1.25E-02 1.65E+00 59 4.25E-02 4.53E-01 4.22E+00

1963 597 1.18E-02 1.63E+00 100 3.65E-02 2.02E-01 2.83E+00

1964 530 6.85E-03 6.90E-01 59 3.09E-02 1.97E-01 3.08E+00

1965 436 1.35E-03 8.00E-02 26 1.66E-02 5.59E-02 2.09E+00

1966 415 2.32E-03 2.00E-01 27 2.54E-02 8.95E-02 2.15E+00

1967 370 1.71E-03 2.50E-01 20 2.06E-02 7.14E-02 2.13E+00

1968 469 1.75E-03 3.50E-01 <10 1.10E-01 6.84E-01 3.04E+00

1969 577 20 (a) 0.00E+00 <10

1970 580 1.60E-03 3.20E-01 29 1.61E-02 7.47E-02 2.54E+00

1971 575 9.39E-04 2.00E-01 16 2.02E-02 9.09E-02 2.50E+00

1972 195 1.19E-02 4.26E-01 68 2.04E-02 8.61E-02 2.40E+00

1973 199 9.86E-02 1.81E+01 69 1.87E-02 1.09E-01 2.91E+00

1974 169 1.30E-02 8.80E-02 67 2.86E-02 6.89E-02 1.71E+00
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Table 6-5: Statistical Parameters of Recorded Penetrating Annual Doses

Year

Arithmetic, All Recorded Dose Lognormal, Dose>0

No. of 

Workers

Dose, rem Dose, rem

Mean Maximum GSD

No. of 

Workers Median 95%

1975 150 5.72E-03 8.60E-02 44 1.25E-02 5.96E-02 2.58E+00

1976 126 9.65E-03 2.48E-01 53 1.37E-02 7.34E-02 2.77E+00

1977 123 5.45E-03 3.00E-01 12 2.76E-02 1.72E-01 3.04E+00

1978 152 7.53E-03 1.25E-01 18 4.55E-02 2.25E-01 2.64E+00

1979 162 2.69E-03 8.30E-02 17 2.12E-02 5.64E-02 1.81E+00

1980 185 4.19E-03 1.33E-01 22 2.74E-02 8.49E-02 1.99E+00

1981 210 4.12E-03 1.20E-01 24 2.72E-02 9.27E-02 2.11E+00

1982 209 2.00E-03 5.20E-02 22 1.67E-02 3.72E-02 1.63E+00

1983 226 2.98E-03 3.14E-01 12 2.76E-02 2.06E-01 3.39E+00

1984 216 1.89E-02 3.57E+00 18 2.44E-02 2.80E-01 4.41E+00

1985 201 4.67E-02 8.66E+00 49 1.41E-02 8.34E-02 2.95E+00

1986 194 3.22E-03 5.50E-02 27 2.05E-02 4.71E-02 1.66E+00

1987 196 1.65E-03 4.00E-02 20 1.18E-02 4.82E-02 2.35E+00

1988 188 3.52E-03 1.80E-01 11 4.62E-02 1.81E-01 2.29E+00

1989 233 8.03E-04 1.60E-02 17 1.09E-02 1.37E-02 1.15E+00

1990 217 1.16E-03 4.10E-02 17 1.37E-02 2.50E-02 1.44E+00

Source: This table is a slightly modified version of Table 15 in ORAUT-TKBS-0031.

(a) All 1969 recorded doses = zero. However, NIOSH can bound these doses using Section 2.1.2 of OCAS-IG-001, 

External Dose Reconstruction Implementation Guideline (Revision 3) and the KCP minimum detection level of 40 mrem. 

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by 

NIOSH

The feasibility determinations for the class of employees under evaluation in this report are governed 

by both EEOICPA and 42 C.F.R. § 83.13(c)(1). Under that Act and rule, NIOSH must establish 

whether or not it has access to sufficient information either to estimate the maximum radiation dose 

for every type of cancer for which radiation doses are reconstructed that could have been incurred 

under plausible circumstances by any member of the class, or to estimate the radiation doses to 

members of the class more precisely than a maximum dose estimate. If NIOSH has access to 

sufficient information for either case, NIOSH would then determine that it would be feasible to 

conduct dose reconstructions. 

In determining feasibility, NIOSH begins by evaluating whether current or completed NIOSH dose 

reconstructions demonstrate the feasibility of estimating with sufficient accuracy the potential 

radiation exposures of the class. If the conclusion is one of infeasibility, NIOSH systematically 

evaluates the sufficiency of different types of monitoring data, process and source or source term data, 

which together or individually might assure that NIOSH can estimate either the maximum doses that 

members of the class might have incurred, or more precise quantities that reflect the variability of 

exposures experienced by groups or individual members of the class. This approach is discussed in 

DCAS’s SEC Petition Evaluation Internal Procedures which are available at 

http://www.cdc.gov/niosh/ocas. The next four major subsections of this Evaluation Report examine:
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• The sufficiency and reliability of the available data. (Section 7.1) 

• The feasibility of reconstructing internal radiation doses. (Section 7.2) 

• The feasibility of reconstructing external radiation doses. (Section 7.3) 

• The bases for petition SEC-00210 as submitted by the petitioner. (Section 7.4) 

7.1 Pedigree of Kansas City Plant Data

This subsection answers questions that need to be asked before performing a feasibility evaluation. 

Data Pedigree addresses the background, history, and origin of the data. It requires looking at site 

methodologies that may have changed over time; primary versus secondary data sources and whether 

they match; and whether data are internally consistent. All these issues form the bedrock of the 

researcher’s confidence and later conclusions about the data’s quality, credibility, reliability, 

representativeness, and sufficiency for determining the feasibility of dose reconstruction. The 

feasibility evaluation presupposes that data pedigree issues have been settled. 

7.1.1 Internal Monitoring Data Pedigree Review

NIOSH has not discovered any bioassay data and has limited air monitoring data from which to 

determine worker doses during natural uranium operations from May 1, 1950 through February 28, 

1955. However, NIOSH has source term data in the form of shipping transactions and accountability 

and contractual records of uranium materials to be processed by KCP. The data sources are copies of 

original reports and contracts and are therefore considered primary data sources. The data reported by 

AEC representatives would have been collected in accordance with standard practices using state-ofthe-art methods of the day. 

NIOSH has not discovered any bioassay data from which to determine worker doses for the Mg-Th 

work performed during the period from May 1, 1957 through April 30, 1979. However, there are air

monitoring data from May 23, 1958 through July 26, 1971, as well as routine, quarterly contamination

surveys for 1959 through 1969. These data are copies of original reports and are therefore considered 

primary data sources. NIOSH also captured uranium bioassay results processed by KCP for radiation 

workers from August 11, 1959 to December 10, 1971. These results are copies of original reports and 

are also considered primary data sources.

7.1.2 External Monitoring Data Pedigree Review

Data for the period from January 1, 1949 through December 31, 1993, consist of radiation survey 

reports. These surveys are copies of original reports and are therefore considered primary data 

sources. NIOSH also captured results of radiation workers’ external dosimetry. These results are 

copies of original reports and are therefore considered primary data sources. 
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7.2 Evaluation of Bounding Internal Radiation Doses at Kansas City Plant

The principal source of internal radiation doses for members of the class under evaluation was the 

potential inhalation and ingestion of airborne uranium and thorium by employees, both those nearby 

and those directly involved in machining at KCP. Other employees nearby were potentially exposed 

to the resuspension of surface contamination during the course of their work with non-radioactive 

materials. The following subsections address the ability to bound internal doses, methods for 

bounding doses, and the feasibility of internal dose reconstruction. 

7.2.1 Evaluation of Bounding Process-Related Internal Doses

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related internal doses of members of the class under evaluation. 

7.2.1.1 Urinalysis Information and Available Data 

NIOSH has 2,809 urinalysis results for the period from September 1, 1959 through December 31, 

1971, and NIOSH plans to use those data to reconstruct doses for workers (Monitoring, 1958-1970; 

Monitoring, 1950-2003; Monitoring, 1963-1970; Monitoring, 1964-1967). 

There was also a urinalysis program for Rockwell employees during D&D activities from June 1, 

1984 through September 3, 1986 (Rockwell, 1985). Internal doses to Rockwell employees can be 

reconstructed using that data.

7.2.1.2 Airborne Levels

NIOSH has identified air monitoring data obtained during routine air sampling for uranium from May 

23, 1958 to July 26, 1971 (Monitoring, 1963-1967; Monitoring, 1958-1970), and also from a safety 

survey in August of 1952 (Safety Survey, 1952). In 1970, KCP performed a test run of Mg-Th 

machining operations in the Model Shop and performed an air monitoring assessment of each 

operation. NIOSH has the air concentration results from this assessment (Mg-Th, 1962-1975).

7.2.1.3 Alternative Data Sources for Bounding Internal Dose 

NIOSH has information that KCP machined and handled natural uranium beginning on May 1, 1950 

and continuing through February 1955 (Paine, 1951; Harshman, 1952; KCP, 1950-1963). NIOSH has 

not found reports that indicate this natural uranium work extended beyond this time period. NIOSH 

has detailed information regarding this work and can use Battelle-TBD-6000 to bound internal doses 

during this period and until the KCP urinalysis monitoring program started in 1959. 

NIOSH has information that KCP machined and handled Mg-Th beginning May 1, 1957 through 

April 30, 1979 (KCP, 1950-1963; KCP, 1979, pdf p. 18). NIOSH has not found reports indicating 

that Mg-Th work extended beyond this time period. NIOSH has detailed information regarding the 

Mg-Th work and can use engineered air concentration limits in conjunction with ORAUT-OTIB-0070 

to bound internal doses during this period and until the start of D&D activities on June 1, 1984. 

KCP workers would have also been exposed to thoron (the thorium daughter product) during Mg-Th 

operations. NIOSH will calculate the thoron exposure using the thorium air concentration determined 
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for the exposure period and apply a claimant-favorable factor to arrive at a bounding thoron air 

concentration. 

7.2.2 Evaluation of Bounding Ambient Environmental Internal Doses

The primary and apparently only substance handled in large quantities with a potential for significant

environmental release involved DU from 1958 through 1970. Beginning in 1990, there is assurance 

that no significant environmental releases occurred based on the multi-agency response findings to the 

Pm-147 incident. 

NIOSH can bound ambient environmental doses to KCP personnel using methodology as described in 

Battelle TBD-6000 for the “Other” category of worker. The “Other” category of worker includes 

employees such as those performing primarily administrative and clerical duties with no reason to 

enter the restricted, radiological areas.

7.2.3 Methods for Bounding Internal Dose at Kansas City Plant 

7.2.3.1 Methods for Bounding Operational Period Internal Dose

Internal dose estimates for KCP work evaluated in this report can be bound as detailed in the 

subsections below. 

Natural Uranium Operations from May 1, 1950 through February 28, 1955 

Details regarding KCP’s work from May 1, 1950 through February 28, 1955, that potentially 

generated uranium contamination are provided in Section 5.1.2 of this report.

A chronological list of radioactive materials at KCP (KCP, 1950-1963) states that natural uranium 

components were inspected and assembled in Department 3A of the Main Manufacturing Building 

from May 1950 through February 1955. This document also states that natural uranium machining 

was performed in Department 49X (also known as Area “X”) of the Main Manufacturing Building 

from February 1951 to December 1952. These “machining” operations would likely generate more 

airborne activity than “inspection and assembly” operations. However, NIOSH will assume 

machining operations occurred in both areas from May 1, 1950 through February 28, 1955. 

Departments 3A and 49X were totally enclosed areas and access was controlled with the use of a 

“Permanent Access List” maintained by the Security, Medical and Safety Departments. No women 

were permitted in these areas. Employees that met the medical and security requirements for entry 

had their entries documented on the “Exclusion Area Register” (Medical, 1950-1953; Thiel, 1955; 

ORAUT-TKBS-0031; Schiltz, Aug1962; Stowers, Jun1951; Frazer, 1952).

The uranium that was processed in Departments 3A and 49X was not directly handled in any other 

areas of KCP. Receiving, Internal Transportation, and Shipping areas were the only other areas at 

KCP that handled this material; however, in these areas only uranium that was in containers was 

handled (KCP, 1950-1963). 
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NIOSH has information that KCP machined a total of 313,070 pounds of natural uranium into slugs, 

and had the capacity to produce 1,000 slugs per day. The KCP machining process is well 

documented. The quantity and types of machines are known, as are the sequence and description of 

machining steps. Cutting speeds are also specified (Stowers, Apr1951). It is also known that KCP 

used a very high coolant flow rate (coolant type was Texaco Soluble Oil “C”). Provisions for 

reclamation of scrap material, chips, dust, and oxides were implemented. KCP had designated storage 

areas for raw material, finished metal, and reclaimed waste. KCP also assigned an accountability 

officer to track uranium metal, and uranium metal transportation was always under the supervision of 

a security guard (Paine, 1951).

NIOSH compared the operations and conditions known and postulated for KCP to those used to 

establish “air sampling data for facilities machining uranium” in Battelle-TBD-6000, Table 7.5. To 

accomplish this, NIOSH reviewed a study used as the foundation for radionuclide intake derivations 

related to uranium machining in Battelle-TBD-6000. NIOSH finds The Industrial Hygiene of 

Uranium Fabrication (HASL-39) (Harris, 1958) to be a bounding approximation of KCP work

activities under consideration. Therefore, NIOSH is satisfied that Battelle-TBD-6000 can be used to 

estimate KCP exposures in this case and concludes that internal exposures to KCP employees during 

natural uranium operations can be bound based on the intake rates for machining (1951 to December 

31, 1955) in Battelle-TBD-6000, Table 7.8 for inhalation and Table 7.9 for ingestion. After reviewing 

existing information regarding work controls and limited air sample data, NIOSH finds this approach 

to be adequately conservative and claimant favorable.

Natural Uranium Post-Operations Period from March 1, 1955 to August 31, 1959 

After reviewing existing information regarding work controls and limited air sample data, NIOSH 

selected the job category “operator” from Table 7.5 of Battelle-TBD-6000, from which to determine 

likely air concentration during machining operations. This category is the closest approximation of 

KCP operations during their work with the most potential for generating airborne radioactivity. That 

corresponding air concentration for the “operator” category is 5,480 dpm/m3. 

Using the settling and resuspension method presented in Battelle-TBD-6000, NIOSH estimated the 

airborne concentration after natural uranium operations ceased. The average residual surface

contamination present at the start of the period was estimated based on the air concentration during 

operations, determined above as 5480 dpm/m3. The estimate of surface contamination was made by

assuming continuous settling of this airborne radioactive material at a rate of 0.00075 m/s for 30 days. 

This resulted in an average floor contamination level of 10,650,000 dpm/m2. 

This settled activity is assumed to have been resuspended during ongoing KCP operations with the 

application of a resuspension factor of 1 x 10-5/m to provide an air concentration of 106.5 dpm/m3 (48. 

pCi/m3) on March 1, 1955 for the start of the post-operations period. 

KCP operations did not generate “new” airborne radioactivity until the start of DU machining 

operations on September 9, 1958. Therefore, NIOSH modeled the depletion of the March 1, 1955 

airborne concentration down to the concentration that existed prior to the start of DU machining. 

The first air sample that NIOSH has been able to find after March 1, 1955, was a sample taken on 

May 23, 1958, and the maximum measured air concentration found during this period prior to the start 
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of large-scale DU machining was reported as 4.90 E-11 μCi/ml (49 pCi/m3). This meant that both 

concentrations that NIOSH desired to use in the “depletion” equation from ORAUT-OTIB-0070 were 

essentially the same.

Therefore, NIOSH determined that the best method for estimating internal exposure at KCP after 

natural uranium operations ceased in 1955 until the start of KCP’s urinalysis program in 1959, is to 

use the maximum gross-alpha measured air sample from prior to the start of large-scale DU 

machining (49 pCi/m3

) and assume that concentration remained constant during this post-operations 

period. NIOSH will assume that machine operators in the Main Manufacturing Building breathed air 

at this concentration for 2000 hours per year. 

NIOSH will use methodology described in Battelle-TBD-6000 to determine air concentrations for 

classes of workers that had less exposure potential or spent less time in the Main Manufacturing 

Building than the machine operators. NIOSH will assume that air concentration for the general 

laborers was half the concentration of that for the operators. Supervisors had half the air 

concentration of the general laborers. Other worker types, such as clerical workers, had 10% of the 

supervisors’ air concentration. 

The ingestion rate will be derived with methodologies presented in OCAS-TIB-009.

Mg-Th Operations from May 1, 1957 through April 30, 1979 

From the onset of Mg-Th operations, KCP sought out methods to perform Mg-Th work safely and 

instituted strict operational controls to prevent airborne generation (Mg-Th, 1957-1970, pdf p. 21). 

These operational controls were stricter than those used at AWEs in earlier years, including 

maintaining surface contamination levels in the work area to <2000 dpm/100 cm2 (alpha), the use of 

wet methods, and the use of local ventilation (Foster, unknown date; Thorium, unknown date; Mg-Th, 

unknown date; Mg-Th, 1957-1970, pdf p. 15; Lalli, 1971). KCP also used access lists to promulgate 

which employees had medical approval to perform Mg-Th work, and to control or restrict entries into 

the work area (Lalli, 1971; Burchett, 1972; Renick, 1972).

In 1957 at the beginning of Mg-Th operations, KCP established engineered airborne limits and 

controlled these operations so as to not exceed 9E-11 μCi/ml (Th-232). KCP also instituted an 

industrial hygiene and fire protection limit of 0.1 mg/m3

 (thorium) (Thorium, unknown date). 

NIOSH examined the implication of this 9E-11 μCi/ml control limit. The Mg-Th used at KCP had a 

nominal 3% Th-232 content as a strengthener, alloyed with 97% magnesium. Assuming a Th-232 

specific activity of 1.1E-7 Ci/g, the 9E-11 μCi/ml limit would equate to 0.82 mg/m3 (approximately 

eight times higher than the industrial hygiene limit). When the remaining 97% of magnesium mass is 

added the result is 27.3 mg/m3 of total airborne dust. NIOSH believes this analysis supports the 

selection of these limits as bounding airborne concentrations in a typical industrial environment 

because of a similar evaluation performed for the Bethlehem Steel site. An evaluation performed by 

Wesley R. Van Pelt Associates for the S. Cohen & Associates review of the Bethlehem Steel Site 

Profile concluded that about 30 mg/m3 provides a plausible upper bound dust concentration for 

continuous exposure in the work place (SC&A, 2005). NIOSH observed similarities in the type of 

work performed at both KCP and Bethlehem Steel and believes the comparison to be relevant and 

applicable to the KCP model. 
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In 1959, KCP lowered their control limit to 3E-11 μCi/ml (Th-232) (Mg-Th, 1957-1970, pdf pp. 14-

16). 

KCP performed gross alpha fixed-filter air monitoring from 1958 through 1971 in the Main 

Manufacturing Building and maintained operations at: 2.85E-12 μCi /ml (average measured level for 

the period) and <8.55E-11 μCi /ml (maximum measured level for the period) ORAUT-TKBS-0031, 

pdf p. 20). 

In 1970, KCP performed an evaluation of Mg-Th machining operations in the Model Shop and 

validated that their process did not generate airborne radioactivity. As part of this test, each 

machining station was evaluated with breathing-zone air samplers running while performing the 

machining operation. KCP machinists maintained airborne levels during this test at background (0

cpm recorded) for long-lived activity, and <3.22E-9 μCi/ml for short-lived activity. Direct-probe 

surveys of the Mg-Th are shown as: 0.3-1.2 mr/hr for beta-gamma radiation, and 250-700 cpm alpha 

(Mg-Th, 1962-1975). 

From May 1, 1957 through October 31, 1959, internal exposures can be bound by using KCP’s initial 

engineered limit of 9E-11 μCi/ml and applying it as a constant. 

NIOSH will assume that machine operators in the Main Manufacturing Building breathed air at this 

concentration for 2,000 hours per year.

NIOSH will use the methodology described in Battelle-TBD-6000 to determine air concentrations for 

classes of workers that had less exposure potential or spent less time in the Main Manufacturing 

Building than the machine operators. NIOSH will assume that the air concentration for general 

laborers was half the concentration of that of the operators. The supervisors of the operators and 

general laborers had half the concentration of the general laborers’ concentration. All other worker 

types, such as those performing primarily administrative and clerical duties with no reason to enter the 

restricted, radiological areas, had 10% of the supervisors’ concentration. 

From November 1, 1959 through April 30, 1979, when Mg-Th operations ceased, the lowered 

engineered limit of 3E-11 μCi/ml can be applied as a constant. 

NIOSH will assume that machine operators in the Main Manufacturing Building breathed air at this 

concentration for 2,000 hours per year. 

NIOSH will use the methodology described in Battelle-TBD-6000 to determine air concentrations for 

classes of workers that had less exposure potential or spent less time in the Main Manufacturing 

Building than the machine operators. NIOSH will assume that the air concentration for general 

laborers was half the concentration of that of the operators. The supervisors of the operators and 

general laborers had half the concentration of the general laborers’ concentration. All other worker 

types, such as those performing primarily administrative and clerical duties with no reason to enter the 

restricted, radiological areas, had 10% of the supervisors’ concentration. 

The ingestion rate will be derived with methodologies presented in OCAS-TIB-009. 
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The thoron exposure bounding basis uses the highest 1970 short-lived sample (3.2E-9 μCi/ml), which 

yields an exposure rate of 5.1 WLM/yr. This amount will be assigned for each year of Mg-Th work. 

Thorium and Thoron Exposures during Mg-Th Post-Operations Period from May 1, 1979 through 

May 31, 1984 

NIOSH assumes that air concentration at the end of operations was the lower limit of 3E-11 μCi/ml 

(66.6 dpm/m3) and that radioactive material was deposited on the floor with a deposition velocity of 

0.00075 m/s for a period of 30 days. This settled activity was then resuspended during KCP 

operations and was depleted until the initial D&D characterization survey on May 31, 1984. 

 

The settling of the final air concentration yields a surface contamination level of 1.3 E5 dpm/m2

(alpha) on June 1, 1979. Applying a resuspension factor of 1E-5/m, yields an air concentration of 1.3 

dpm/m3 (0.59 pCi/ m3) for the start of the post-operations period on June 1, 1979. 

A characterization survey was performed prior to D&D activities. The maximum “accessible” 

contamination level was 6E4 dpm/m2. Applying a resuspension factor of 1E-5/m, yields an air 

concentration of 0.6 dpm/m3 (0.27 pCi/ m3

) for the end of the post-operations period on May 31, 

1984. 

These two concentrations were inserted into the exponential interpolation (depletion) equation from 

ORAUT-OTIB-0070. 

• λ = -ln(A1984/A1979) /t = 4.23 E-4/yr 

This depletion rate (4.23 E-4/yr) will be applied to the initial air concentration to determine the 

remaining activity available for inhalation and ingestion for each year of this post-operations period. 

NIOSH will assume that machine operators in the Main Manufacturing Building breathed air at this 

concentration for 2,000 hours per year. 

NIOSH will use the methodology described in Battelle-TBD-6000 to determine air concentrations for 

classes of workers that had less exposure potential or spent less time in the Main Manufacturing 

Building than the machine operators. NIOSH will assume that the air concentration for general 

laborers was half the concentration of that of the operators. Supervisors had half the concentration of 

the general laborers’ concentration. All other worker types, such as those performing primarily 

administrative and clerical duties with no reason to enter the restricted, radiological areas, had 10% of 

the supervisors’ concentration. 

The ingestion rate will be derived with methodologies presented in OCAS-TIB-009. 

The thoron exposure bounding basis for this post-operations period will start the period at 5.1 

WLM/yr as derived above and will use the same depletion rate (4.23 E-4/yr) to determine the 

exposure to assign for each year of this May 1, 1979 through May 31, 1984, post-operations period. 
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Uranium Exposures during the Mg-Th Post-Operations Period from May 1, 1979 through May 31, 

1984 

NIOSH will use uranium residual data to bound exposures to KCP personnel that performed work in 

areas adjacent to the Mg-Th work area. 

The maximum measured surface contamination survey taken during DU operations will be used to 

model a starting point air concentration for this post-operational period. The value of 45,000 dpm/100 

cm2 (4.5 E6 dpm/m2 alpha) was re-suspended during KCP operations and was depleted until the initial 

D&D characterization survey on May 31, 1984. 

 

Applying a resuspension factor of 1E-5/m, yields an air concentration of 45 dpm/m3 (20.3 pCi/ m3) for 

the start of the post-operations period on May 1, 1979. 

A characterization survey was performed prior to D&D activities. The maximum “accessible” 

contamination level was 6E4 dpm/m2

. Applying a resuspension factor of 1E-5/m, yields an air 

concentration of 0.6 dpm/m3 (0.27 pCi/ m3

) for the end of the post-operations period on May 31, 

1984. 

These two concentrations were inserted into the exponential interpolation (depletion) equation from 

ORAUT-OTIB-0070. 

• λ = -ln(A1984/A1979) /t = 2.36 E-3/yr 

This depletion rate (2.36 E-3/yr) will be applied to the initial air concentration to determine the 

remaining activity available for inhalation and ingestion for each year of this post-operations period. 

NIOSH will assume that machine operators in the Main Manufacturing Building breathed air at this 

concentration for 2,000 hours per year. 

NIOSH will use the methodology described in Battelle-TBD-6000 to determine air concentrations for 

classes of workers that had less exposure potential or spent less time in the Main Manufacturing 

Building than the machine operators. NIOSH will assume that the air concentration for general 

laborers was half the concentration of that of the operators. Supervisors had half the concentration of 

the general laborers’ concentration. All other worker types, such as those performing primarily 

administrative and clerical duties with no reason to enter the restricted, radiological areas, had 10% of 

the supervisors’ concentration. 

The ingestion rate will be derived with methodologies presented in OCAS-TIB-009. 

D&D Activities from June 1, 1984 through September 3, 1986 

Rockwell employees that performed the D&D work would have most likely received the highest 

exposures during this D&D period. The Rockwell Final Report states that continuous in-progress 

radiologic surveys were performed as concrete and drain system removal progressed. Although 

moderate levels of fixed DU contamination were located throughout this area, no significant radiation 

hazards were identified in the course of this effort and personnel encountered no radiation exposure 

problem in the area (Rockwell, 1985, pdf p. 25). 
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Bioassay by means of urinalysis for uranium and blood testing for lead was utilized as a means of 

assessing internal deposition of hazardous materials in Rockwell personnel. Baseline samples prior to 

assignment of work and quarterly samples thereafter were obtained from each worker that entered the 

contaminated areas during D&D operations (Rockwell, 1985, pdf p. 25). 

Rockwell workers had barriers around their work and used continuous air monitors outside their 

perimeter, monitoring for U-238 at a control level of 1E-12 μCi/ml (Rockwell, 1985, pdf p. 25). 

NIOSH will use urinalysis for Rockwell D&D workers and assume that KCP employees were 

exposed at the perimeter air-concentration level during this period. 

7.2.3.2 Methods for Bounding Ambient Environmental Internal Dose 

As stated above for the various time periods, NIOSH will use the methodology described in BattelleTBD-6000 to determine air concentrations for classes of workers that had less exposure potential or 

were unmonitored for internal exposures. NIOSH will assume that the air concentration for general 

laborers was half the concentration of that of the operators. Supervisors had half the concentration of 

the general laborers’ concentration. All other worker types, such as those performing primarily 

administrative and clerical duties with no reason to enter the restricted, radiological areas, had 10% of 

the supervisors’ concentration. 

Using available KCP workplace-control and monitoring information, with methods available in 

Battelle-TBD-6000, NIOSH concludes it is feasible to bound internal ambient radiation doses for 

unmonitored workers for the period from January 1, 1949 through December 31, 1993 at KCP. 

7.2.4 Internal Dose Reconstruction Feasibility Conclusion 

NIOSH concludes that there are methods available in Battelle-TBD-6000 and ORAUT-OTIB-0070, as 

well as breathing zone air data, bioassay data, and operational descriptions, so that uranium, thorium, 

and thoron internal radiation doses can be completely reconstructed with sufficient accuracy for KCP

workers from January 1, 1949 through December 31, 1993. 

7.3 Evaluation of Bounding External Radiation Doses at Kansas City Plant

The primary sources of workplace radiation fields at KCP are historically associated with processes 

involving industrial radiation-generating devices (e.g., X-ray machines and electron accelerators) (see 

Table 5-2) and isotopic beta, gamma-ray, and neutron radiation-emitting sources (see Table 5-3). 

KCP workers were also potentially exposed to gamma and beta radiation associated with handling and 

working in proximity to uranium and thorium. Some employees were also potentially externally 

exposed to radiation from resuspended contamination from uranium and thorium metal surfaces and 

the floor during the course of their work with these materials. 

The following subsections address the ability to bound external doses, methods for bounding doses, 

and the feasibility of external dose reconstruction. 
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7.3.1 Evaluation of Bounding Process-Related External Doses

NIOSH has located external monitoring records for neutron, beta, and gamma radiation for KCP

workers associated with uranium and thorium processing during the class period under evaluation. 

Individual dosimetry data are the preferred data source for evaluating the external radiation doses for 

members of the KCP class. 

NIOSH has access to 13,846 external dosimetry records that include monitoring data for deep dose, 

shallow dose, extremity dose (rings), and neutron dose for the years 1950 through 1993. KCP 

participated in Department of Energy Laboratory Accreditation Program (DOELAP) performance

testing using Landauer-provided services beginning in October 1992. 

KCP performed extremity monitoring with ring dosimeters 1,853 times from 1950 to 1993. Positive 

results were recorded 635 times with the highest dose being 4.448 rem, recorded in 1952. 

NIOSH has knowledge of the neutron, beta, and photon (X-ray and gamma) dosimeters used at KCP. 

They include: 

• Landauer Neutrack I Dosimeter: This dosimeter was used at KCP from 1991 through 1993 to 

measure neutron doses. It is a polycarbonate (Lexan) neutron recoil track registration device used 

to monitor fast neutron interactions. It has a uniform energy response from 3 to over 14 MeV with 

a threshold of 1 MeV. 

• Other neutron dosimeters used at KCP included: Controls for Radiation from 1961 to 1967, 

Landauer film from 1967 to 1973, Landauer NTA film from 1974 to 1982, and Landauer Lexan 

track-etch from 1983 to 1990. 

• Pocket Ionization Chamber (PIC): This is a self-reading instrument that provides the user with 

“real-time” data, with which the user can better manage their exposure. The PIC also provided 

KCP with the ability to exercise administrative control until dosimeter results were available. The 

PICs were not used to generate a dose of record. 

• KCP Film Dosimeter: This dosimeter is a two-piece, stainless-steel, film holder with front and rear 

matching rectangular windows. The front and rear faces have a 1-mm thick cadmium filter in the 

area of the open window. Two different types of personal dosimetry film packets are used in this 

dosimeter: Kodak Type-2 for mixed beta and gamma radiation and DuPont Type-558 for X-ray

and gamma radiation. The DuPont Type-558 film packet contains two films, Type-508 and Type1290. The Type-508 film has a range of 0.003 to 30 R, and Type-1290 has a range of 0.68 to 

3,000 R. KCP calibration data using uranium and Co-60 sources are available (Bendix, 1964). 

This dosimeter was used at KCP from 1950 through 1972. 

• KCP thermoluminescent dosimeter (TLD) (two-chip,): This dosimeter was used from 1973 to 

1982 at KCP.

• Eberline Standard (three-chip, TLD-100) TLD: This TLD was used from 1983 through 1990 at 

KCP. This dosimeter employs one chip under a 10-mg/cm2 filter to measure the shallow or skin 

dose, and one or two chips under a 285-mg/cm2 filter to measure the deep or whole-body dose 

(ORAUT-TKBS-0031). The use of this dosimeter was terminated due to its inability to pass 
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DOELAP lower energy photon performance testing categories (although it had passed National 

Voluntary Laboratory Accreditation Program testing) (AlliedSignal, 1991).

• Landauer K1 (three-chip, TLD-700) TLD: This TLD was used beginning April 1, 1991, to 

measure beta, X-ray, and gamma radiation exposure to KCP workers. 

During the D&D operations from 1984 to 1986, Rockwell’s final report stated that the total exposure 

from the job was expected to be less than 0.4 man rem for each of the three phases (Rockwell, 1985, 

pdf pp. 103, 114, 123, 137). Rockwell personnel exposure was measured with film badges and no 

measurable doses of radiation were incurred by any member of the decontamination crew (Rockwell, 

1985, pdf p. 54).

The available personnel external monitoring data discussed in Section 6.2 of this report, obtained from 

Neutrack film badges, TLDs, and pocket ionization chambers, provide external photon, beta, and

neutron dose information for the personnel working during the evaluated period at KCP. These data 

can be used to reconstruct dose for members of the class under evaluation. While external dosimetry

data are not available for all members of the class under evaluation, monitoring data do exist for some 

KCP employees within the class being evaluated. As discussed in this evaluation, the available 

personnel monitoring data include data that represent the maximally-exposed work group and work 

scenario during the KCP evaluated period. NIOSH believes that external monitoring data obtained 

from workers associated with the production activities can be used to bound external exposures to all 

members of the class under evaluation. Therefore, NIOSH has concluded that the available personnel 

monitoring data and information for KCP support its ability to bound the external dose for the class 

under evaluation. 

7.3.2 Evaluation of Bounding Ambient Environmental External Doses

KCP prepared a Site Safety Assessment report in 1995 in compliance with DOE requirements 

(AlliedSignal, Sep1995). The report concluded that KCP operations had produced no undue hazard to 

the general public and had no significant effect on the environment. Air and water effluents have been 

monitored routinely to assess compliance with relevant criteria. KCP has routinely handled hazardous 

chemicals, with limited handling of radioactive materials and thus essentially little likelihood of a 

significant occupational environmental exposure associated with releases. KCP has generated lowlevel radioactive waste that includes equipment radiation sources, tritium exit signs, irradiated 

components, gap tubes, smoke detectors, small amounts of cleanup materials, and personal protective 

equipment. Mixed wastes consisted of encapsulated electronic assemblies. 

NIOSH had found no indication that ambient external radiation fields were a significant contribution 

to worker doses at KCP. NIOSH concludes it is feasible, using available external monitoring data for 

KCP radiation workers and methods available in the KCP Site Profile (ORAUT-TKBS-0031) and 

ORAUT-OTIB-0020, to bound external ambient radiation doses for unmonitored workers for the 

period from January 1, 1949 through December 31, 1993 at KCP. 

7.3.3 Kansas City Plant Occupational X-Ray Examinations 

Starting in 1949 as part of the requirements for employment at KCP, employees received preemployment, periodic, and/or termination physical examinations (Todd, Apr2004). These physical 
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examinations might have included radiographic examinations of the chest to screen for disease. The 

medical X-ray units used for these exams belonged to and were operated by the KCP Medical 

Department (ORAUT-TKBS-0031, pdf p. 14). 

All workers, including fire, patrol, radiation, and cafeteria workers, received a chest X-ray during the 

pre-employment examination and annually thereafter until the mid-1980s when it was discontinued 

(Todd, Jun2004; Todd, Aug2004; Brendlinger, 1974; Stowers, Aug1951). Several sources mention 

that the chest X-ray consisted of a single Posterior-Anterior (PA) projection (Monitoring, 1976; 

Brendlinger, 1974; Jacobson, 1988; Todd, Jun2004). This is evident from the claim-file records, as 

LAT chest X-rays are rare. Beginning in 1993, chest X-rays were taken every five years or more

frequently if worker history or physical circumstances indicated the need. Based on a review of X-ray 

films from the 1950s and 1960s conducted by KCP staff, there is no evidence that photofluorography 

was used at KCP (Todd, Aug2004). 

Therefore, NIOSH concludes that it is feasible to reconstruct occupational medical dose for KCP

workers with sufficient accuracy. 

7.3.4 Methods for Bounding External Dose at Kansas City Plant 

There is an established protocol for assessing external exposure when performing dose reconstructions 

(these protocol steps are discussed in the following subsections): 

• Photon Dose 

• Beta Dose

• Neutron Dose 

• Medical X-ray Dose (as applicable per Section 7.3.3) 

7.3.4.1 Methods for Bounding Operational Period External Dose 

Beta and Photon Dose 

Beta and photon doses to KCP personnel can be reconstructed using available external dosimetry

reports for all years associated with the evaluated period. 

The DOE-reported photon deep dose for KCP workers is expected to provide a reasonable estimate of 

the actual photon dose. Dosimetry technology is capable of detecting and measuring the photon dose 

based on studies of historical performance (NBS, 1955; Unruh, 1967). The energy of prevalent 

photons based on the radiation sources is readily measured, so no adjustment of recorded dose would 

be likely based on the response characteristics of the different dosimeters.

Neutron Dose 

Neutron doses to KCP personnel can be reconstructed using available external dosimetry reports for 

all years associated with the evaluated period. 

Positive neutron doses were recorded at KCP a total of 34 times over a period from 1966 through 

1993, with most instances occurring in the 1980s. In all but two cases the recorded annual deep dose 
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is equal to the recorded annual neutron, implying all recorded deep dose resulted from the neutron 

dose. The two exceptions occurred in 1976 and 1983 with recorded deep and neutron annual doses of 

64 mrem and 26 mrem, and 3 mrem and 1 mrem, respectively. 

NIOSH can bound neutron doses to workers where it finds dosimetric photon monitoring results for a 

worker. If NIOSH determines that there was a potential unmonitored neutron exposure, then a 

neutron-to-photon dose ratio of 1:1 as a conservative estimate of neutron dose will be used. Overall, 

the recorded neutron dose is a relatively insignificant component of the worker dose. The recorded 

neutron dose must be adjusted to include conversion to the International Commission on Radiological 

Protection (ICRP) Publication 60 (1991) neutron weighting.

Because there are no workplace measurements of neutron spectra, NIOSH’s analysis assumed that

100% of the workplace neutron radiation is within the range of 0.1 to 2 MeV. This option provides 

the highest organ dose estimate. The approach can be simplified using the following expression: 

Neutron dose = adjusted photon dose × upper 95th-percentile neutron/photon dose ratio × ICRP 60 

DCF

Medical X-ray Dose 

NIOSH has data sufficient to support establishing a bounding dose estimate for the medical X-ray

doses to members of the evaluated class. 

A revision to the Site Profile for the Kansas City Plant, ORAUT-TKBS-0031, has updated X-ray 

information that NIOSH will use to bound these KCP X-ray exposures. It includes dose equivalents 

from PA chest X-ray examinations for each period and skin dose equivalents. From 1949 through 

1985, NIOSH will assume that KCP personnel received preemployment, annual, and termination PA 

chest X-rays. From 1986 through 1993, NIOSH will assume KCP personnel received annual and 

termination PA chest X-rays.

7.3.4.2 Methods for Bounding Ambient Environmental External Doses 

NIOSH has data sufficient to support establishing a bounding dose estimate for the ambient 

environmental external doses to members of the evaluated class.

NIOSH had found no indication that ambient external radiation fields were a significant contribution 

to worker doses at KCP. NIOSH can bound ambient environmental doses to KCP for the “Other” 

category of worker. The “Other” category of worker includes employees such as those performing 

primarily administrative and clerical duties with no reason to enter the restricted, radiological areas.

NIOSH concludes it is feasible, using available external monitoring data for KCP radiation workers 

and methods available in the KCP Site Profile (ORAUT-TKBS-0031) and ORAUT-OTIB-0020, to 

bound external ambient radiation doses for unmonitored workers for the period from January 1, 1949 

through December 31, 1993 at KCP. 
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7.3.5 External Dose Reconstruction Feasibility Conclusion 

Due to the availability of external personal monitoring data throughout the period under evaluation, 

NIOSH considers reconstruction of external radiation dose to be feasible for KCP workers for the 

period from January 1, 1949 through December 31, 1993. NIOSH also considers reconstruction of 

medical X-ray dose to be feasible.

7.4 Evaluation of Petition Basis for SEC-00210

The following subsections evaluate the assertions made on behalf of petition SEC-00210 for the KCP 

site. 

7.4.1 Class Definition

Issue: The petitioner requested that the evaluated class include all members of the BFC.

NIOSH Response: The BFC is not a covered facility as defined by EEOICPA. KCP, located within 

the BFC, is a covered facility. This issue is further addressed in Section 3.2 of this report.

7.4.2 Promethium Contamination Incident 

Issue: The petitioner identified the “Promethium Contamination Incident” in 1989 as an unmonitored, 

unrecorded, or inadequately monitored exposure incident.

NIOSH Response: After viewing detailed information regarding this incident, NIOSH has determined 

it can bound exposures during the event with available personal monitoring records. This issue is 

addressed in Section 5.2.3 of this report. 

7.4.3 DU Machining 

Issue: The petitioner stated that workers machined DU product and were not monitored. 

NIOSH Response: After viewing detailed information regarding DU machining, NIOSH has 

determined it can bound exposures during the operations with available personal monitoring records. 

This issue is addressed in Section 7 of this report. 

7.4.4 Unmonitored Exposure

Issue: The petitioner stated that there were unmonitored exposures, including the following:

many surface and airborne uranium isotopes, plutonium, tritium, weapons grade uranium-235, 

uranium-233, neutrons and other ionizing radiation from industrial X-ray gauging devices, electron 

beam welders, neutron generators, neutron plutonium-beryllium sources, accelerators, cesium 

irradiator, medical X-ray, and Electro Curtain. 

NIOSH Response: After viewing detailed process and source-term information regarding these issues, 

and considering the external and internal monitoring data available, NIOSH has determined it has 

sufficient information to document potential exposures and bound associated doses. 
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7.5 Summary of Feasibility Findings for Petition SEC-00210

This report evaluates the feasibility for completing dose reconstructions for employees at KCP from 

January 1, 1949 through December 31, 1993. NIOSH found that the available monitoring records, 

process descriptions and source term data available are sufficient to complete dose reconstructions for 

the evaluated class of employees.

Table 7-1 summarizes the results of the feasibility findings at KCP for each exposure source during 

the time period from January 1, 1949 through December 31, 1993. 

Table 7-1: Summary of Feasibility Findings for SEC-00210

January 1, 1949 through December 31, 1993

Source of Exposure Reconstruction Feasible Reconstruction Not Feasible

Internal1 X 

 - Natural Uranium X

 - Depleted Uranium X

 - Thorium X

 - Thoron X

External X 

 - Gamma X

 - Beta X

 - Neutron X

 - Occupational Medical X-ray X

Note:

1 Internal includes an evaluation of urinalysis (in vitro), airborne dust data, documented operational controls process 

descriptions, and source term data. 

As of November 22, 2013, a total of 665 claims have been submitted to NIOSH for individuals who 

worked at KCP during the period under evaluation in this report. Dose reconstructions have been

completed for 608 individuals (~91.4%). 

8.0 Evaluation of Health Endangerment for Petition SEC-00210

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by both EEOICPA and 42 C.F.R. § 83.13(c)(3). Under these requirements, if it is not 

feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH must 

also determine that there is a reasonable likelihood that such radiation doses may have endangered the 

health of members of the class. Section 83.13 requires NIOSH to assume that any duration of 

unprotected exposure may have endangered the health of members of a class when it has been 

established that the class may have been exposed to radiation during a discrete incident likely to have 

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If 

the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

required to specify that health was endangered for those workers who were employed for a number of 

work days aggregating at least 250 work days within the parameters established for the class or in 
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combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

NIOSH’s evaluation determined that it is feasible to estimate radiation dose for members of the 

NIOSH-evaluated class with sufficient accuracy based on the sum of information available from 

available resources. Therefore, a health endangerment determination is not required. 

9.0 Class Conclusion for Petition SEC-00210

Based on its full research of the class under evaluation, NIOSH found no part of said class for which it 

cannot estimate radiation doses with sufficient accuracy. This class includes all employees who 

worked in any area of the Kansas City Plant site in Kansas City, Missouri, from January 1, 1949 

through December 31, 1993. 

NIOSH has carefully reviewed all material sent in by the petitioner, including the specific assertions 

stated in the petition, and has responded herein (see Section 7.4). NIOSH has also reviewed available 

technical resources and many other references, including the Site Research Database (SRDB), for 

information relevant to SEC-00210. In addition, NIOSH reviewed its NOCTS dose reconstruction 

database to identify EEOICPA-related dose reconstructions that might provide information relevant to 

the petition evaluation. 

These actions are based on existing, approved NIOSH processes used in dose reconstruction for 

claims under EEOICPA. NIOSH’s guiding principle in conducting these dose reconstructions is to 

ensure that the assumptions used are fair, consistent, and well-grounded in the best available science. 

Simultaneously, uncertainties in the science and data must be handled to the advantage, rather than to 

the detriment, of the petitioners. When adequate personal dose monitoring information is not 

available, or is very limited, NIOSH may use the highest reasonably possible radiation dose, based on 

reliable science, documented experience, and relevant data to determine the feasibility of 

reconstructing the dose of an SEC petition class. NIOSH contends that it has complied with these 

standards of performance in determining the feasibility or infeasibility of reconstructing dose for the 

class under evaluation.
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10.0 References 

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, p. 22,296; May 2, 2002; SRDB Ref ID: 19391 

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

19392 

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 

2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001 

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation 

Program Act of 2000, as amended

AlliedSignal, 1989, Report of Investigation of Pm-147 Contamination February 10, 1989; 

AlliedSignal Aerospace Company; published September 1989; SRDB Ref ID: 79842 

AlliedSignal, 1991, Remedial Action Plan for DOE Laboratory Accreditation Program (DOELAP); 

Allied-Signal Inc. Kansas City Division; revised: February 22, 1991; SRDB Ref ID: 14680 

AlliedSignal, Mar1995, Kansas City Plant Hazard Assessment, Rev. 2; AlliedSignal Aerospace 

Company-Kansas City Division; March 1995; SRDB Ref ID: 53178 

AlliedSignal, Sep1995, Site Safety Assessment for the Kansas City Plant; AlliedSignal Aerospace; 

September 1995; SRDB Ref ID: 14890 

Battelle-TBD-6000, Site Profiles for Atomic Weapons Employers that Worked Uranium Metals, Rev. 

01; effective June 17, 2011; SRDB Ref ID: 101251 

Bendix, 1964, Film Dosimetry Manual; The Bendix Corporation, Kansas City Division; January 6, 

1964; SRDB Ref ID; 14684 

Brendlinger, 1974, MOCA Physicals, correspondence to Jim. Morris; R. L. Brendlinger; May 30, 

1974; SRDB Ref ID: 128146 

Burchett, 1972, Physical Examination and Orientation-Magnesium Thorium, correspondence to C. W. 

Jones; C. E. Burchett; November 27, 1972; SRDB Ref ID: 128158, pdf p. 2 
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Cone, 1950, Radioactivity-Control, correspondence to Mr. Evans; L. Cone; January 23, 1950; SRDB 

Ref ID: 123900, pdf pp. 10-11 

DCAS-PR-004, Internal Procedures for the Evaluation of Special Exposure Cohort Petitions, Rev. 1, 

National Institute for Occupational Safety and Health (NIOSH); Cincinnati, Ohio; April 15, 2011; 

SRDB Ref ID: 94768 

DOE, 2010, EEOICPA Search Procedures-KCP Record Source Descriptions; Records Source was 

DOE Germantown; printed November 29, 2010; SRDB Ref ID: 93380 

DOE, Mar2013, Description of Current Conditions Report for the Bannister Federal Complex 

(Section 7-Presence of Depleted Uranium and Beryllium at the BFC and Current and Potential 

Future Impacts on the Environment); Department of Energy (DOE); March 2013 draft; SRDB Ref ID: 

127484 

DOE, May2013, Final Environmental Assessment for the Transfer of the Kansas City Plant, Kansas 

City, Missouri, DOE/EA-1947; Department of Energy (DOE)/National Nuclear Security 

Administration (NNSA); May 2013; SRDB Ref ID: 127459 

Foster, unknown date, A Survey of Existing Facilities at Bendix, Kansas City for Machining and 

Fabrication of Thorium; Robert Foster; unknown date; SRDB Ref ID: 128170 

Frazer, 1952, Bendix Aviation Corporation, Kansas City Division-Roster of Department 49B; J. C. 

Frazer and J. W. Faulkenberry; January 16, 1952; SRDB Ref ID: 128336 

Grant, 1962, Radiation in Connection with Bendix Red Bank Spark Gaps, correspondence to J. O. 

Schiltz; Paul Grant; June 18, 1962; SRDB Ref ID: 123900, pdf p. 49 

Harris, 1958, The Industrial Hygiene of Uranium Fabrication, HASL-39; William B. Harris and 

Irving Kingsley; June 6, 1958; SRDB Ref ID: 15785 

Harshman, 1952, Tonawanda Area Progress Report; K. J. Harshman; August 22, 1952; SRDB Ref 

ID: 77595 

Hobert, 1953, History of Fernald Liaison Office, DPF-53-132; R. H. Hobert; June 11, 1953; SRDB 

Ref ID: 76834 

Jacobson, 1988; Diagnostic X-Ray System Evaluation, correspondence to J. G. Ochoa; Gerald A. 

Jacobson; October 27, 1988; SRDB Ref ID: 128151, pdf pp. 3-6 

KCP, 1950-1963, Chronological List of Radioactive Materials in the Plant; dates in document ranging 

from January 1950 through January 8, 1963; SRDB Ref ID: 128349, pdf pp. 2-17 
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KCP, 1962, The Fluorophotometric Determination of Uranium in Urine; Kansas City Plant (KCP); 

August 20, 1962; SRDB Ref ID: 14691 

KCP, 1979, Prohibition of Eating, Drinking and Smoking at Work Stations, Attachment; Kansas City 

Plant (KCP); April 5, 1979; SRDB Ref ID: 121164, pdf p. 18 

KCP, 2004, Summary of KCP Responses to List of Information Needs; June 23, 2004; SRDB Ref ID: 

14695 

KCP, unknown date, Uranium in Urine and Lead List; unknown date; SRDB Ref ID: 14694 

Laing, 1952, April Triple Dip Canning Program, correspondence to L. R. Kelman; E. C. Laing; April 

5, 1952; SRDB Ref ID: 101212 

Lalli, 1971, Handling Magnesium-Thorium in Dept. 851; prepared by F. E. Lalli; July 15, 1971; 

SRDB Ref ID: 128155 

Mahaffey, 1952, History of Production Machining of Uranium, FMPC-28; James W. Mahaffey; June 

16, 1952; SRDB Ref ID: 44238 

Malone, Feb1952, Weekly Progress Report-February 14, 1952; F. W. Malone, Tonawanda SubOffice; February 18, 1952; SRDB Ref ID: 73509 

Malone, Mar1952, Weekly Progress Report-February 28, 1952; F. W. Malone, Tonawanda SubOffice; March 3, 1952; SRDB Ref ID: 73512 

Maroncelli, 2002, The Traveler’s Guide to Nuclear Weapons; James M. Maroncelli and Timothy L. 

Karpin; first published 2002; SRDB Ref ID: 44825 

Medical, 1950-1953, Various Correspondence regarding Physical Examinations for Area 3A and 

Work Assignment Information; various authors; dates ranging from July 1950 through January 1953; 

SRDB Ref ID: 128319 

Mg-Th, 1957-1970, Multiple Health and Safety Guidance Documents/Correspondence regarding 

Handling Magnesium-Thorium; multiple authors; dates range from September 5, 1957 through August 

24, 1970; SRDB Ref ID: 128181 

Mg-Th, 1962-1975, Multiple Documents (Correspondence, Guidance, Authorizations) regarding 

Magnesium-Thorium; multiple authors; various dates ranging from 1962 through 1975; SRDB Ref ID: 

108264 

Mg-Th, unknown date, Magnesium-Thorium Alloy Information; unknown author; unknown date; 

SRDB Ref ID: 128161 
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Monitoring, 1950, Personnel Dosimetry Report for 1950; results for dates between May 1950 through 

August 1950; SRDB Ref ID: 123899 

Monitoring, 1950-2003, External Doses and Total Uranium Intakes Spreadsheet from a KCP Query 

of the KCP Site Database; Data for CY 1950 through 2003; SRDB Ref ID: 14707 

Monitoring, 1958-1961, Radiation Contamination Determinations and Special Materials Monitoring 

Records for 1958 through 1961; results for dates between January 1958 through December 1961; 

SRDB Ref ID: 128377 

Monitoring, 1958-1970, Maximum Annual Air Concentrations Sample Results; Data for CY 1958 

through 1970; SRDB Ref ID: 14716 

Monitoring, 1958-2005, Uranium Bioassay Data Results and Correspondence regarding Results for 

October 1958 through February 2005; various dates ranging from October 1958 through February 

2005; SRDB Ref ID: 49002 

Monitoring, 1959-1960, Floor Monitoring Reports for May 1959 through January 1960; multiple

reports for dates ranging from May 1959 through January 1960; SRDB Ref ID: 123889 

Monitoring, 1959-1971, Uranium Bioassay Urine Results and Curve for August 1959 through 

November 1971; various dates ranging from August 1959 through November 1971; SRDB Ref ID: 

128368 

Monitoring, 1960, Floor Monitoring Reports for 1960; multiple reports for dates ranging from 

January 1960 through November 1960; SRDB Ref ID: 123883 

Monitoring, 1962-1969, Air Sample Results by Location for 1962 through 1969; various results for 

dates ranging from January 1962 through December 1969; SRDB Ref ID: 128373 

Monitoring, 1963-1967, Uranium Air Sample Results; various dates from 1963 through 1967; SRDB 

Ref ID: 121164, pdf pp. 20-196 

Monitoring, 1963-1970, Uranium in Urine and Blood Lead Determination Results; various dates from 

1963 through 1970; SRDB Ref ID: 123903 

Monitoring, 1964-1967, Uranium in Urine and Blood Lead Determination Results; various dates from 

May 1964 through September 1967; SRDB Ref ID: 123908 

Monitoring, 1965-1969, Floor Monitoring Reports for July 1965 through August 1969; multiple

reports for dates ranging from July 1965 through August 1969; SRDB Ref ID: 123896 
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Monitoring, 1967-1983, Film Badge Exposure Date for January 1967 through December 1983; 

various dates ranging from January 1967 through December 1983; SRDB Ref ID: 128404 

Monitoring, 1969-1970, Air Sample Results by Location for December 1969 through December 1970; 

various dates ranging from December 1969 through December 1970; SRDB Ref ID: 128390 

Monitoring, 1969-1971a, Results of Uranium Bioassay in Urine for November 1969 through October 

1971; various dates ranging from November 1969 through October 1971; SRDB Ref ID: 128366 

Monitoring, 1969-1971b, Results of Uranium in Urine and Blood Lead Tests for February 1969 

through December 1971; various dates ranging from February 1969 through December 1971; SRDB 

Ref ID: 128384 

Monitoring, 1970-1971, U-238 Air Sample Results for December 1970 through July 1971; various 

dates ranging from December 1970 through July 1971; SRDB Ref ID: 128206 

Monitoring, 1974-1978, Film Badge Exposure Date for December 1974 through January 1978; 

various dates ranging from December 1974 through January 1978; SRDB Ref ID: 128403 

Monitoring, 1976, Radiation Protection Survey; survey dated October 10, 1976; SRDB Ref ID: 

128476, pdf p. 2 

Monitoring, 1990-1996, Multiple Documents (correspondence, survey results) regarding Tear-Down 

Area Survey Results ranging from July 1990 through February 1996; various dates between July 1990 

through February 1996; SRDB Ref ID: 128417 

Nasca, 2004a, KCP Radiation Exposure History, electronic correspondence; Brent Nasca; March 31, 

2004; SRDB Ref ID: 15929 

Nasca, 2004b, Discussion of Unexplained Dose Readings, electronic correspondence; Brent Nasca; 

April 2, 2004; SRDB Ref ID: 14708 

NBS, 1955, Intercomparison of Film Badge Interpretations; National Bureau of Standards (NBS); 

April 1955; SRDB Ref ID: 3640 

OCAS-IG-001, External Dose Reconstruction Implementation Guideline, Rev. 3; Office of 

Compensation Analysis and Support; effective November 21, 2007; SRDB Ref ID: 38864 

OCAS-TIB-009, Estimation of Ingestion Intakes, Rev. 0; Office of Compensation Analysis and 

Support; effective April 13, 2004; SRDB Ref ID: 22397 

O’Leary, 1951, Meeting with DuPont to Discuss DuPont’s Dissatisfaction with Uranium Supply 

Picture; W. J. O’Leary; November 26, 1951; SRDB Ref ID: 10118 
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ORAUT-OTIB-0006, Dose Reconstruction from Occupationally Related Diagnostic X-Ray 

Procedures, Rev. 04; ORAU Dose Reconstruction Team; effective June 20, 2011; SRDB Ref ID: 

98147 

ORAUT-OTIB-0020, Use of Coworker Dosimetry Data for External Dose Assignment, OCAS-TIB0020, Rev. 3; ORAU Dose Reconstruction Team; effective November 14, 2011; SRDB Ref ID: 

104029

ORAUT-OTIB-0070, Dose Reconstruction during Residual Radioactivity Periods at Atomic Weapons 

Employer Facilities; ORAU Dose Reconstruction Team; effective March 5, 2012; SRDB Ref ID: 

108851

ORAUT-TKBS-0031, Site Profile for the Kansas City Plant, Rev. 00 PC-1; ORAU Team Dose 

Reconstruction Project for NIOSH; ORAU Dose Reconstruction Team; effective January 6, 2006; 

SRDB Ref ID: 20217 

Paine, 1951, Machining of U-238; W. B. Paine; September 13, 1951; SRDB Ref ID: 75263 

Personal Communication, 2013a, Personal Communication with KCP Health Physicist; Interview by 

ORAU Team and NIOSH; August 27, 2013; SRDB Ref ID: 127865 

Personal Communication, 2013b, Personal Communication with Former KCP Employee; Interview 

by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127871

Personal Communication, 2013c, Personal Communication with Former KCP Employee; Interview 

by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127869 

Personal Communication, 2013d, Personal Communication with Former KCP Employee; Interview 

by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127875 

Personal Communication, 2013e, Personal Communication with Former KCP Employee; Interview 

by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127868 

Personal Communication, 2013f, Personal Communication with Former KCP Employee; Interview by 

ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127873 

Personal Communication, 2013g, Personal Communication with Former KCP Employee; Interview 

by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127863

Personal Communication, 2013h, Personal Communication with Former KCP Employee; Interview 

by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127878 
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Personal Communication, 2013i, Personal Communication with Former KCP Employee; Interview by 

ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127872 

Personal Communication, 2013j, Personal Communication with Former KCP Employee; Interview by 

ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127877 

Personal Communication, 2013k, Personal Communication with Former KCP Employee; Interview 

by ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127876 

Personal Communication, 2013l, Personal Communication with Former KCP Employee; Interview by 

ORAU Team and NIOSH; August 28, 2013; SRDB Ref ID: 127864 

Personal Communication, 2013m, Personal Communication with Former KCP Employee; Interview 

by ORAU Team and NIOSH; August 29, 2013; SRDB Ref ID: 127874

Personal Communication, 2013n, Personal Communication with KCP Employee; Interview by ORAU 

Team and NIOSH; August 29, 2013; SRDB Ref ID: 127866 

Personal Communication, 2013o, Personal Communication with Former KCP Employee; Interview 

by ORAU Team and NIOSH; August 29, 2013; SRDB Ref ID: 127870 

Personal Communication, 2013p, Personal Communication with Former KCP Employee; Interview 

by ORAU Team and NIOSH; August 29, 2013; SRDB Ref ID: 127867 

Personal Communication, 2013q, Personal Communication with Former KCP Employee; Interview 

by ORAU Team and NIOSH; August 29, 2013; SRDB Ref ID: 128746 

Personal Communication, 2013r, Personal Communication with KCP Employee; Interview by ORAU 

Team and NIOSH; October 16, 2013; SRDB Ref ID: 128743 

Personal Communication, 2013s, Personal Communication with Former KCP Employee; Interview by 

ORAU Team and NIOSH; August 29, 2013; SRDB Ref ID: 128748 

Personal Communication, 2013t, Personal Communication with KCP Health Physicist; e-mail 

correspondence by ORAU Team; September 4, 2013; SRDB Ref ID: 127657 

Personal Communication, 2013u, Personal Communication with KCP Employees; e-mail 

correspondence by ORAU Team; November 27, 2013; SRDB Ref ID: 129196

Purchase Order, 1962, Purchase Order ICO-020757 to Union Carbide and Nuclear Corporation for 

10,000 Pounds of Uranium-Dioxide; order date is July 19, 1962; SRDB Ref ID: 14683 
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Rad Handbook, 1970, Radiological Health Handbook, Revised Edition; compiled and edited by the 

Bureau of Radiological Health and the Training Institute Environmental Control Administration; 

revised January 1970; SRDB Ref ID: 75017 

Rad Handling, 1987, Multiple Correspondence and Documents regarding Radionuclide 

Handling/Inventory at Kansas City Plant; multiple authors; various dates throughout 1987; SRDB Ref 

ID: 108242 

Rad Inventory, 1989, Radioactive Material Inventory Form; dated April 3, 1989; SRDB Ref ID: 

128430, pdf pp. 41-42 

Renick, 1972, Health and Hygiene Clearances, correspondence to Clyde Jones; H. N. Renick; 

November 22, 1972; SRDB Ref ID: 128158, pdf p. 3 

Rockwell, 1985, Waste Trenches and Machining Area Decontamination Final Report, Volume 1 

Executive Summary, RI/RD85-265-1; Rockwell International; October 30, 1985; SRDB Ref ID: 

123905 

Rockwell, 1987, Heavy Machining Inspection Area Decontamination, Final Report, RI/RD87-138; 

Rockwell International; March 12, 1987; SRDB Ref ID: 123906 

Safety Survey, 1952, Safety Survey for August 4-7, 1952; Survey write-up dated August 28, 1952; 

SRDB Ref ID: 128316 

SC&A, 2005, Draft Advisory Board on Radiation and Worker Health, First Supplemental Review of 

the Bethlehem Steel Site Profile, ORAUT-TKBS-0001, Draft Rev. 2; S. Cohen & Associates (SC&A); 

September 2005; SRDB Ref ID: 27979 

Schiltz, Jun1962, Request for Radioisotope Information Contained in Spark Gap Tube, 

correspondence; J. O. Schiltz; June 15, 1962; SRDB Ref ID: 123900, pdf p. 50 

Schiltz, Aug1962, Experience with Radioactive Sources at Bendix Corporation Prior to 1954 (T219 

Testing), attachment to correspondence; J. O. Schiltz; August 17, 1962; SRDB Ref ID: 128310, pdf 

pp. 106-112 

Stowers, Apr1951, Machining of U-238, correspondence to W. B. Paine; James C. Stowers; April 23, 

1951; SRDB Ref ID: 128332, pdf p. 3 

Stowers, Jun1951, Procedures Pertaining to Work Performed in Area X, correspondence to W. B. 

Paine; James C. Stowers; June 8, 1951; SRDB Ref ID: 128333 

Stowers, Aug1951, Safety Regulations for Handling and Storing Normal Uranium; James C. Stowers; 

August 17, 1951; SRDB Ref ID: 128346 
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Thiel, 1955, Exit Physical Examinations, correspondence; G. E. Thiel; March 1, 1955; SRDB Ref ID: 

128320 

Thorium, unknown date, Thorium Exposure Levels and Handling Instructions, first page is missing; 

unknown author; unknown date; SRDB Ref ID: 128148 

Todd, Apr2004, KCP Occupationally Related Routine Chest X-Rays, e-mail correspondence; Marcia 

Todd; April 8, 2004; SRDB Ref ID: 14701 

Todd, Jun2004, KCP Medical X-Rays, e-mail correspondence; Marcia Todd; June 2, 2004; SRDB Ref 

ID: 14702 

Todd, Aug2004, Questions for KCP Technical Basis Document; e-mail correspondence; Marcia Todd; 

August 19, 2004; SRDB Ref ID: 14706 

Trip Report, 1949, Visit to Bendix Aviation Co. on May 25, 1949; A. R. Piccot; trip reported dated 

June 29, 1949; SRDB Ref ID: 75265 

Tritium Incident, 1987, Multiple Documents regarding Possible Exposure to Radioactive Material, 

Erbium Tritide Particulate Inside Contaminated MC3847; October 1987; SRDB Ref ID: 108267 

Ulitchny, 1998, Uranium Dioxide Powder; M. G. Ulitchny, G. L. Ross, and C. E. Evans; October 

1998; SRDB Ref ID: 14693 

Unruh, 1967, The Establishment and Utilization of Film Dosimeter Performance Criteria, BNWL542; C. M. Unruh, H. V. Larson, T. M. Beetle, and A. R. Keene; September 1967; SRDB Ref ID: 

14914 
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Attachment One: Data Capture Synopsis

Table A1-1: Summary of Holdings in the SRDB for KCP

Data Capture Information Data Capture Description Completed Uploaded 

into SRDB

Primary Site / Company Name: Kansas City 

Plant; DOE 1949 - Present

Contractors: 

Honeywell FM&T (1999 - Present); AlliedSignal Aerospace / formerly Bendix (1949 - 

1999)

Physical Size of the Site: 1999 - ~3.2 million 

square feet. New location currently relocating 

to is 1.5 million square feet.

Site Population: 1997 is ~3,455; 1998 is 

~2,981; 2013 is ~2,700

 

Annual report test laboratory department 213, Landauer exposure results, 

annual report for emissions of radionuclides, annual environmental report, 

air sample results, ALARA information, radiation and contamination 

surveys, area TLD information, building floor plans and property layout, 

film badges calibration, chronological list of radioactive materials in the 

plant, personnel entry into areas, decontamination reports, termination 

reports, evaluation of the X-ray fluorescence method, gap tubes documents, 

hydrogen-tritium getters, medical X-ray information, machining of U-238, 

magnesium-thorium alloy information, bioassay results, incident reports, 

radionuclide emissions reports, trip reports, safety survey, shipping 

documents for radioactive waste, source program data, thorium exposure 

levels and handing instructions, Troxell vs. Bendix files, waste trenches and 

machining area decontamination final report.

11/21/2013 1,202

State Contacted: NA NOTE: Contacting the state was not considered necessary KCP is an active 

DOE site and cooperated with relevant data collection.

12/12/2013 0

Brookhaven National Laboratory Compilation of ambient air monitoring parameters. 03/01/2006 1

Claimant Provided Exposure information and air sample results. 12/14/2012 2

Department of Labor / Paragon Production, operational, and progress reports. 01/23/2012 7

DOE Germantown Search procedures and a plant mission policy. 08/08/2012 4

DOE Legacy Management - Grand Junction 

Office

Weekly progress reports, environmental assessment, machining of U-238, 

trip report, triple dip canning program, shipment of rods, and a low-level 

waste disposal capacity report.

08/29/2011 15

DOE Legacy Management - MoundView 

(Fernald Holdings, includes Fernald Legal 

Database)

Incineration of radioactive solid wastes, annual radionuclide air emission 

report, history of production machining of uranium, and a tritium feasibility 

study.

05/18/2010 6

DOE OSTI History of the production complex and environmental restoration and waste 

management site maps and facilities listings.

05/17/2007 2

Federal Records Center - Atlanta Personnel external dosimetry quality assurance. 03/19/2004 1

Federal Records Center - Kansas City Health Physics audit by DOE Headquarters, radiological protection 10/10/2013 57
SEC-00210 01-07-2014 Kansas City Plant

66 of 70 

Table A1-1: Summary of Holdings in the SRDB for KCP

Data Capture Information Data Capture Description Completed Uploaded 

into SRDB

procedures, bioassay results, dosimeter issue report, radiological surveys, 

Health and Safety guide for handling magnesium-thorium, TLD lab 

certificate of accreditation, radioactive waste inventories, radiation 

monitoring service results, source leak tests, ionizing and non-ionizing 

radiation-generating equipment inventory, personnel radiation dosimetry 

report, radiation protection program manual, segregation and disposing of 

radioactive waste, ALARA report, and radiological incidents.

Federal Records Center - Lenexa Personnel exposure data. 10/24/2013 10

Hanford DOE site profiles. 01/12/2013 1

Idaho National Laboratory DOELAP application information. 06/11/2009 2

Internet - Defense Technical Information 

Center (DTIC)

Uranium alloy metallurgy, LANL institutional plan, and an annual report to 

Congress.

01/09/2012 4

Internet - DOE Comprehensive Epidemiologic 

Data Resource (CEDR)

No relevant documents identified. 12/04/2013 0

Internet - DOE Hanford Declassified Document 

Retrieval System (DDRS)

Monthly reports. 10/24/2008 2

Internet - DOE Legacy Management 

Considered Sites

Mixed waste inventory report and a progress report. 04/23/2013 2

Internet - DOE National Nuclear Security 

Administration (NNSA) - Nevada Site Office

No relevant documents identified. 04/22/2013 0

Internet - DOE Environmental Management Linking Legacies - Wastes. 10/28/2007 1

Internet - DOE OpenNet Radiation safety and major activities in the atomic energy programs, history 

of nuclear weapons program, weapons production schedule, and a 

purchase order summary.

03/30/2012 8

Internet - DOE OSTI Energy Citations Fifty year history of the chemical technology division at Argonne National 

Laboratory, annual report of waste generation, progress report, program 

summary, bioaccumulation monitoring and toxicity testing in streams and 

groundwater wells, and occupational radiation exposure.

02/01/2013 10

Internet - DOE OSTI Information Bridge Environmental management progress and plans, report of radioactive waste 

inventory, report to Congress, descriptions of representative contaminated 

sites and facilities within the DOE Complex, summary of radionuclide air 

emissions, transportation and disposal configuration for DOE - managed 

low-level and mixed low-level waste quarterly report, annual programmatic 

reports, low-level waste inventory, naturally occurring arsenic in the 

groundwater at the Kansas City Plant, routine environmental audit, and a 

01/26/2013 35
SEC-00210 01-07-2014 Kansas City Plant

67 of 70 

Table A1-1: Summary of Holdings in the SRDB for KCP

Data Capture Information Data Capture Description Completed Uploaded 

into SRDB

short history of plutonium in the US and Russia.

Internet - DOE OSTI SciTech Connect No relevant documents identified. 04/22/2013 0

Internet - EECAP No relevant documents identified. 12/04/2013 0

Internet - Google Accelerating cleanup - paths to closure, ALARA analysis, onsite review 

report, relocating Rocky Flats plutonium operations, scope of prime 

contractor at Kansas City Plant, application of plasma shield technology, 

area air and surface dust monitoring report, legacy contamination 

clarification, DOE activities and plans, development of radiological profiles 

for low-level mixed wastes, occupational radiation exposure records, 

environmental assessment, toxicological profile for uranium, program 

assessment, events at the Rocky Flats site from the 1930s to present, final 

environmental assessment for the transfer of Kansas City Plant, improving 

the scientific basis for managing excess nuclear materials and spent nuclear 

fuel, Kansas City Plant mission and history, KCP Pm 147 contamination, 

area air and surface dust monitoring report, nuclear matters a practical 

guide, nuclear weapons complex weaknesses, and DOE stockpile 

stewardship program.

10/24/2013 123

Internet - Health Physics Journal No relevant documents identified. 12/04/2013 0

Internet - Journal of Occupational and 

Environmental Hygiene

No relevant documents identified. 12/04/2013 0

Internet - National Academies Press (NAP) Nuclear weapons complex management for health, safety, and the 

environment.

05/28/2010 1

Internet - NIOSH Report on residual radioactive and beryllium contamination. 06/07/2007 1

Internet - NRC Agencywide Document Access 

and Management (ADAMS) 

Integrated data base on spent fuel and radioactive waste inventories and a 

final programmatic environmental impact statement for stockpile 

stewardship.

09/16/2012 7

Internet - USACE/FUSRAP No relevant documents identified. 04/23/2013 0

Internet - US Transuranium and Uranium 

Registries

No relevant documents identified. 04/22/2013 0

Kansas City Plant / SC&A Department D/435 NFE shielding evaluation of leakage/exposure issues, 

bioassay results, promethium-147 investigation committee report, Health 

Physics appraisal, unusual occurrence reports, radiological surveys, lowlevel beta radiation detected in D/456 and D/33, radioactive waste 

inventories, precious materials inventories, magnesium-thorium in 

department 851, technical safety appraisal, nuclear safety program 

08/19/2013 41
SEC-00210 01-07-2014 Kansas City Plant

68 of 70 

Table A1-1: Summary of Holdings in the SRDB for KCP

Data Capture Information Data Capture Description Completed Uploaded 

into SRDB

appraisal, and employee dosimeter assignments.

Landauer Client (site) List No relevant documents identified. 12/12/2013 0

Los Alamos National Laboratory Radioactive waste disposal and an environmental assessment. 12/06/2007 2

Missouri Department of Natural Resources Draft environmental impact statement, environmental, plutonium working 

group safety and health vulnerabilities report, and an emergency plan.

10/01/2008 9

Mound Museum Manufacturing statement for weapons production schedule of transfers. 05/18/2010 3

National Archives and Records Administration 

(NARA) - Atlanta

Inspections at Kansas City Plant and United Nuclear Corporation Hematite 

Plant, indoor radon study, radioactive material shipments, and an industrial 

accident summary.

10/20/2005 5

National Archives and Records Administration 

(NARA) - Atlanta / SC&A

Pinellas, Mound, Kansas City Inhalation Toxicology Research Institute 

Ram Inventories.

08/12/2004 1

National Archives and Records Administration 

(NARA) - Lee's Summit

Exposure information. 10/14/2008 2

National Institute for Occupational Safety and 

Health (NIOSH)

Magnesium-thorium alloys industrial health experience in fabrication and 

production and AEC history.

08/27/2012 11

New York State Archives Shipment and storage of radioactive waste. 03/19/2012 1

Nevada Test Site Final environmental impact statement. 10/01/2003 1

Nuclear Regulatory Commission (NRC) Public 

Document Room

Industrial health experience with magnesium-thorium alloys. 11/01/2006 1

Ohio Department of Health Report on residual radioactive and beryllium contamination. 11/20/2007 1

ORAU Team Documented communication on thorium oxide powder/gap tubes/ uranium 

and thorium machining/ tritides, recommendations on neutron weighting 

factors, ambient environmental dose, and occupational X-ray dose.

12/03/2013 29

SAIC Radiation exposure summary. 09/02/2004 4

Sandia National Laboratory (SNL) - NM Tritium bioassay data, Ross Aviation shipment surveys and shipping 

documents, and Ross Aviation laboratory surveys.

10/20/2010 5

Savannah River Site Dosimetry visitor cards. 08/26/2008 1

SC&A / Idaho National Laboratory Environmental survey and preliminary report. 06/24/2010 1

SC&A / Kansas City Plant Internal dosimetry radiation monitoring for personnel working with 

depleted uranium.

07/23/2013 1

SC&A / Nevada Test Site Report of Santa Fe Operations Office. 06/24/2010 1

SC&A / Pinellas Plant Annual report on waste generation and minimization progress. 06/24/2010 1

SC&A / Sandia National Laboratory - CA Albuquerque Operations annual report. 02/16/2009 1

SC&A / Sandia National Laboratory - NM Radiological surveys. 09/15/2010 3

Southern Illinois University AEC construction cost differentials. 10/15/2008 1
SEC-00210 01-07-2014 Kansas City Plant

69 of 70 

Table A1-1: Summary of Holdings in the SRDB for KCP

Data Capture Information Data Capture Description Completed Uploaded 

into SRDB

Unknown Radiological incidents, operations, and safety, Rocky Flats site history, 

decommissioning information, investigations and summary reports of 

thorium, occupational radiation exposure reports, annual reports, and DOE 

waste management operations.

10/04/2004 13

Y-12 Radioactive material shipment inspection reports. 05/16/2012 2

Total 1,645

Table A1-2: Database Searches for KCP

Database/Source Keywords Hits Uploaded 

into SRDB

NOTE: Database search terms employed for each of the databases listed below are available

in the Excel file called “Copy of Kansas City Plant Rev 00 12-18-13.”

Defense Technical Information Center (DTIC)

https://www.dtic.mil/

COMPLETED 12/04/2013

See Note above 231 0 

DOE CEDR

http://cedr.lbl.gov/

COMPLETED 12/04/2013

See Note above 0 0 

DOE Hanford DDRS

http://www2.hanford.gov/declass/

COMPLETED 04/22/2013

See Note above 0 0 

DOE Legacy Management Considered Sites

http://csd.lm.doe.gov/

COMPLETED 04/23/2013

See Note above 0 0 

DOE NNSA - Nevada Site Office

www.nv.doe.gov/main/search.htm

COMPLETED 04/22/2013

See Note above 0 0 

DOE OpenNet

http://www.osti.gov/opennet/advancedsearch.jsp

COMPLETED 04/22/2013

See Note above 1,818 1 

DOE OSTI Energy Citations

http://www.osti.gov/energycitations/ See Note above 73,290 12
SEC-00210 01-07-2014 Kansas City Plant

70 of 70 

Table A1-2: Database Searches for KCP

Database/Source Keywords Hits Uploaded 

into SRDB

COMPLETED 04/22/2013

DOE OSTI Information Bridge

http://www.osti.gov/bridge/advancedsearch.jsp

COMPLETED 04/22/2013

See Note above 71,367 6 

DOE OSTI SciTech Connect

http://www.osti.gov/home/osti_launch_scitech

COMPLETED 04/22/2013

See Note above 378 0 

Energy Employees Claimant Assistance Project 

(EECAP)

http://www.eecap.org/index.htm

COMPLETED 12/04/2013

See Note above 1 0 

Google

http://www.google.com

COMPLETED 08/28/2013

See Note above 968,692,676 120

HP Journal

http://journals.lww.com/healthphysics/pages/default.aspx

COMPLETED 12/04/2013

See Note above 45 0 

Journal of Occupational and Environmental Health 

http://www.ijoeh.com/index.php/ijoeh

COMPLETED 12/04/2013

See Note above 11 0 

National Academies Press

http://www.nap.edu/

COMPLETED 04/23/2013

See Note above 8,206 1 

NRC ADAMS Reading Room

http://www.nrc.gov/reading-rm/adams/webbased.html

COMPLETED 04/22/2013

See Note above 4,202 0 

USACE/FUSRAP

http://www.lrb.usace.army.mil/fusrap/

COMPLETED 04/23/2013

See Note above 0 0 

U.S. Transuranium & Uranium Registries 

http://www.ustur.wsu.edu/

COMPLETED 04/22/2013

See Note above 0 0